With the European Union’s Digital Operational Resilience Act (DORA) now firmly embedded in the regulatory landscape, financial institutions across Europe are transitioning from regulatory interpretation to operational execution. While DORA has been extensively analysed since its adoption, many organisations are now facing a more practical challenge: how to implement its most demanding requirements in a way that strengthens real-world resilience rather than simply satisfies compliance expectations.
At its core, DORA, which applies from 17 January 2025, reshapes how financial institutions manage digital risk. It requires banks, insurers, trading venues, and other critical financial entities can withstand and quickly recover from ICT disruptions, whether caused by technical failures, cyber-attacks, or third-party incidents. For boards, CISOs, and risk leaders, this is more than regulatory compliance; it’s about protecting reputation, customer trust, and the stability of the financial system itself.
Among DORA’s advanced security requirements is Threat-Led Penetration Testing (TLPT), a step beyond traditional pen tests. In our experience TLPT uncovers operational risks that standard pen tests often miss. TLPT combines the rigor of red teaming with intelligence-driven scenarios, simulating realistic attacks against live production environments. Unlike standard vulnerability assessments or pen testing, Threat-Led Penetration Testing exposes institutions to the same threats they would face from sophisticated adversaries, testing not just defences but also detection, response, and recovery capabilities end-to-end.
With regulators expecting implementation on a strict timeline and reputational stakes higher than ever, the message for financial institutions is clear: now is the time to act. We’ve guided multiple institutions through early TLPT planning, and those that start now are far better prepared for both compliance and real-world threats.
Understanding Threat-Led Penetration Testing and preparing to integrate it into your operational resilience programme will be crucial for meeting DORA requirements and demonstrating that your organisation can survive, adapt, and respond to real-world cyber threats.
Threat-Led Penetration Testing (TLPT) is an intelligence-driven red team exercise designed to test an organisation’s cybersecurity defences in the most realistic way possible. Unlike traditional penetration tests, which often focus on finding technical vulnerabilities in isolated systems, TLPT simulates how actual adversaries would attack your live production environment, including technology, critical business services, operational processes, and the people who operate and defend them.
The key difference between Threat-Led Penetration Testing and standard penetration testing or vulnerability assessments lies in depth, realism, and scope:
What makes TLPT uniquely powerful is its integration of threat intelligence and realistic attack scenarios. Testers follow end-to-end kill chains, mapping how relevant threat actors, whether cybercriminal groups, nation-state sponsored actors, or other adversaries aligned to the organisation’s threat landscape, might breach defences, move laterally, and impact critical services.
This approach exposes not only technical vulnerabilities but also gaps in detection, response, and recovery. This provides organisations with actionable insights to strengthen resilience before a real attack occurs.
Under DORA, not every financial institution is required to perform Threat-Led Penetration Testing. The rules focus on those with the most significant impact on the EU financial system. Specifically, TLPT applies to:
In terms of frequency, DORA mandates that TLPT be conducted at least once every three years. However, regulators have discretion to require more or less frequent testing if an institution’s risk profile, size, or systemic importance warrants it. This ensures that testing keeps pace with evolving threats and changing operational environments, reinforcing the EU’s emphasis on continuous digital operational resilience.
DORA’s Regulatory Technical Standards (RTS) set clear expectations to enable Threat-Led Penetration Testing is robust, independent, and risk focused.
These requirements ensure TLPT provides a credible, regulator-aligned assessment of an institution’s true operational resilience.
A DORA-aligned Threat-Led Penetration Testing follows a structured lifecycle designed to deliver realism while maintaining control and regulatory oversight.
This phase defines clear objectives and ensures operational risk is managed.
The goal is to test end-to-end detection, response, and containment, not just technical weaknesses.
The control team oversees risk, communications, and regulatory coordination throughout the exercise, ensuring the test remains controlled, aligned, and safe while preserving realism by maintaining secrecy around the exercise.
Threat-Led Penetration Testing delivers far more than technical findings. It provides a real-world test of operational resilience. By executing sophisticated, intelligence-led attacks, institutions gain an authentic assessment of their detection, response, and recovery capabilities against the types of adversaries most likely to target them. This moves testing beyond theoretical controls, ensuring that identifying and closing attack paths delivers measurable ROI and cost avoidance.
Threat-Led Penetration Testing outcomes also directly support broader DORA obligations. Findings feed into:
At a business level, the benefits are equally compelling. Effective Threat-Led Penetration Testing reduces the likelihood of material cyber incidents, strengthens confidence among regulators, and reinforces customer trust in the institution’s ability to safeguard critical services.
Ultimately, it helps reduce systemic risk, positioning the organisation as resilient, credible, and prepared in an increasingly hostile threat landscape. While fostering a culture of continuous improvement in the face of evolving threats.
SecAlliance delivers intelligence-led, regulator-aligned Threat-Led Penetration Testing to financial institutions as part of a broader cyber threat intelligence and resilience offering. Our TLPT engagements are grounded in real-world threat analysis and tailored to the specific risks faced by EU financial entities under DORA.
At the core of SecAlliance’s approach is the provision of actionable, intelligence-led insights that shape red team testing, ensuring realistic, regulator-aligned Threat-Led Penetration Testing. Before any simulated attack, they conduct structured threat and targeting assessments to identify credible adversaries, relevant TTPs, and realistic attack paths based on the institution’s sector, technology environment, geography, and critical functions. These intelligence products then directly shape the TLPT scenarios and testing strategy.
SecAlliance’s differentiators include:
This combination of intelligence depth, regulatory awareness, and operational insight means SecAlliance’s Threat-Led Penetration Testing services help institutions not only meet DORA requirements but also strengthen their overall cyber resilience posture.
DORA’s Threat-Led Penetration Testing requirement is not a distant compliance milestone; it is a strategic resilience obligation that demands action now. From our experience, institutions that start by mapping critical functions, systems, and key third-party dependencies gain the clearest path to actionable TLPT planning.
Financial institutions should begin by confirming whether they fall within scope and gaining clarity on supervisory expectations. From there, mapping critical or important functions, including the ICT systems and key third-party providers that support them, is essential.
An honest assessment of current security maturity should focus on SOC capabilities, detection coverage, and incident response procedures, as well as the readiness of the control team to coordinate with stakeholders, establish independent oversight, and provide clarity on critical processes, systems, and their dependencies. This baseline enables organisations to plan TLPT that is realistic, effective, and aligned with DORA’s intent.
Looking ahead, financial institutions should embed TLPT within a structured ICT resilience testing programme, ensuring it informs risk management, incident response, and third-party oversight rather than sitting in isolation. To get started, organisations should ask themselves:
Answering these questions provides a clear baseline for operational resilience and TLPT readiness. The faster gaps are identified, the sooner institutions can move from theory to practice, ensuring compliance, improving resilience, and reducing risk before a real incident occurs.
Organisations that approach TLPT as a strategic opportunity rather than a regulatory burden will be better equipped to withstand sophisticated attacks, reduce the likelihood of material incidents, and demonstrate confidence to supervisors, boards, and customers. This methodology has also proven highly valuable for non-regulated organisations and industries beyond financial services, where SecAlliance has successfully applied intelligence-led testing to enhance operational resilience.
If you would like to assess your readiness or begin planning your first DORA-aligned Threat-Led Penetration Test, speak with SecAlliance. An intelligence-led, regulator-aligned approach today will position your institution for resilience tomorrow.
