DORA, the EU’s Digital Operational Resilience Act, has been directly applicable law since 17 January 2025, and its testing requirements are where most financial firms run into trouble first. The regulation sets up two genuinely different testing obligations under one name, and conflating them is the single most common mistake we see: basic ICT testing that applies to nearly every in-scope entity every year, and Threat-Led Penetration Testing (TLPT), a far heavier, specialised exercise that only a defined subset of firms ever has to run. This guide separates the two clearly, explains exactly who has to do what, and walks through what a TLPT engagement actually involves phase by phase.








