DORA (Digital Operational Resilience Act) forces organizations to rethink how they manage admin access. The regulation doesn’t just ask for better security practices, it demands ongoing monitoring of ICT systems and visibility into who’s accessing what, when, and why.
That word “continuous” is doing a lot of heavy lifting here. It means the days of “set it and forget it” admin access are over. You can’t audit what you can’t see, and you can’t control what’s always available.
Financial organizations implementing DORA are discovering that traditional approaches to privileged access management create compliance gaps they never saw coming. The solution? Just-in-time privilege management that gives you the granular visibility and control DORA actually demands.
What DORA Requires for Access Control
DORA doesn’t just add another compliance checkbox. It fundamentally changes what regulators expect from privilege management. The regulation introduces specific technical requirements that make traditional “set it and forget it” admin access a compliance liability.
- Continuous Monitoring and Control – Financial entities must implement continuous monitoring and control of ICT systems and tools to provide ongoing protection. This isn’t about quarterly access reviews: it’s about knowing who’s doing what with admin privileges right now.
- Tamper-Proof Audit Trails – The regulation mandates audit trails that must be tamper-proof, secure, and include detailed logs of all ICT incidents. Translation: every admin action needs to be tracked, logged, and ready for regulatory scrutiny.
- Least Privilege is Now Mandatory – Organizations need to ensure employees can only access information necessary for their job. The principle of least privilege is now a regulatory requirement, not just a security best practice.
Where Many Organizations Fall Short
DORA’s requirements are exposing weaknesses in privilege management approaches that worked fine before continuous monitoring became mandatory.
Always-On Administrative Access Problems
Organizations that grant permanent administrative privileges face significant DORA compliance challenges. Users get admin rights and keep them continuously. From a DORA compliance perspective, this approach creates several problems.
With permanent admin access, it becomes difficult to distinguish between routine system maintenance and potentially suspicious activities. Every action occurs within the context of elevated privileges, making it harder to identify anomalous behavior. When users maintain constant administrative access, audit trails become voluminous and difficult to analyze. Regulators reviewing compliance need to understand the business justification for specific elevated actions, which becomes challenging when admin privileges are always active.
Most importantly, permanent admin access inherently violates DORA’s least privilege requirements, as users maintain elevated permissions even when performing routine, non-administrative tasks.
Session-Based Elevation Challenges
Some organizations use session-based approaches where users can elevate their privileges for specific time periods. This provides better alignment with DORA requirements by creating defined windows of administrative access that can be more easily monitored and audited.
However, session-based elevation can still create compliance challenges if the elevation periods are lengthy or if there’s insufficient granularity in what actions are permitted during elevated sessions. For example, granting a user admin rights for an entire 8-hour shift when they only need 20 minutes to install software creates the same audit trail problems as permanent access.
DORA’s continuous monitoring requirements need you to justify why someone had elevated privileges at 3 PM when the actual work happened at 9 AM. Similarly, broad session-based access that allows any administrative action during the window doesn’t satisfy least privilege requirements, even if it’s time-limited.
The Just-in-Time Advantage
Just-in-time privilege management aligns most closely with DORA’s technical requirements by providing privileged access only when specifically needed and only for the duration required to complete a particular task.
Real-Time Visibility
JIT systems provide clear visibility into when administrative access is granted, used, and revoked. This creates the real-time visibility that DORA’s continuous monitoring requirements demand, making it easy to track privileged activities as they happen.
Meaningful Audit Trails
Because JIT access is granted for specific purposes and time windows, audit trails become more meaningful. Each elevation event has a clear business justification, making it easier to demonstrate compliance during regulatory reviews.
Built-in Least Privilege
JIT enforces this requirement by design. Users get exactly the permissions they need, when they need them, and nothing more, with elevation expiring automatically. This eliminates the compliance gaps that come with standing privileges – there’s no guesswork about whether someone’s current access level is appropriate because it’s tied directly to an approved business need.
Proper Role Separation
You need to keep your risk, control, and audit teams separate – that’s basic segregation of duties under DORA. JIT systems support this through role-based approval workflows that automatically route access requests to the appropriate oversight function, conflict prevention that evaluates requests against existing roles, and automatic termination that ensures no lingering permissions create compliance issues.
Examples of Common DORA Scenarios
Looking at how different privilege management approaches handle DORA scenarios shows why JIT access has real advantages.
Emergency System Access During Incidents
DORA requires financial entities to minimize the impact of ICT risk through proper strategies, policies, procedures, and tools. When a critical system goes down at 2 AM, IT teams need immediate admin access to restore services. But DORA also mandates detailed incident reporting within 24 hours, including who accessed what systems and when.
With permanent admin access, it becomes nearly impossible to distinguish between routine maintenance activities and actual incident response actions in the audit logs. JIT systems solve this through “break glass” functionality that provides immediate administrative access during declared incidents while creating detailed audit records that clearly identify emergency access events, who authorized them, and what specific actions were taken. The key is ensuring break glass access has proper controls – time limits, automatic expiration, and approval workflows – so it doesn’t become a backdoor to routine elevated access.
This approach satisfies both operational needs (fast access) and compliance requirements (clear audit trails for incident reporting).
Third-Party Vendor Access
DORA puts a lot of focus on third-party vendors. Organizations need to track their vendor relationships and make sure vendor access gets the same audit treatment as internal users.
Consider a scenario where a database vendor needs emergency access to troubleshoot a performance issue affecting trading systems. With traditional approaches, organizations often create temporary accounts with broad permissions or add vendors to admin groups. Both methods create compliance headaches because the access usually extends beyond what’s actually needed, making it tough to show you’re following least privilege rules.
JIT access lets you give vendors exactly what they need for specific tasks and timeframes. The vendor gets database admin rights for exactly four hours to fix the performance issue, with everything logged and access automatically cut off when time’s up. You get a clear audit trail showing exactly why the vendor needed access, what they could do, and how long they had it.
Regulatory Audit Preparation
When regulators review DORA compliance, they need to understand the business justification for privileged activities across potentially thousands of access events. Traditional models with permanent or long-duration access make this extremely challenging.
Imagine explaining to an auditor why a user had domain admin rights active during a specific two-week period when a security incident occurred. With permanent access, you can’t demonstrate that the privileges were necessary or appropriate for that timeframe. JIT systems make audit preparation straightforward because each access grant is tied to a specific request with documented business need, approval workflow, and automatic expiration.
This granular approach makes regulatory audits much easier because each access event is clearly documented and justified.
The Path Forward for DORA Compliance
DORA’s access control requirements represent a significant shift from previous regulatory approaches. The regulation’s emphasis on continuous monitoring, detailed audit trails, and least privilege access creates clear technical requirements that organizations must address.
The most successful DORA implementations focus on four critical integration areas:
- Identity system integration – JIT solutions should work with existing Active Directory, LDAP, or cloud identity providers
- Security tool compatibility – Privilege management should enhance, not conflict with, existing SIEM, monitoring, and incident response tools
- Workflow automation – Access requests and approvals should integrate with existing ticketing and approval systems
- Audit system connectivity – Privilege logs should feed into existing compliance and audit platforms
As financial organizations work through DORA implementation, the ones that build their systems around what the regulation actually requires will be in much better shape for both compliance and real operational resilience.
Interested in learning more about how Admin By Request can help with DORA compliance? See the specific details here, or check out our full Compliance Mapping page.
