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DORA Major ICT Incident Reporting: Classification Criteria and Reporting Timelines, Explained for Small Financial Entities

2026-10-11 Regulation

How fast do you have to report a major ICT incident under DORA

Once you classify an ICT-related incident as "major," you have to send the initial notification to your competent authority within 4 hours of that classification decision, and in any case no later than 24 hours after you first became aware of the incident. From there, an intermediate report is due within 72 hours of the initial notification, and the final report follows within one month of the intermediate report (or the latest updated intermediate report, if the incident drags on).

Where these numbers actually come from

I say this a lot to clients because people keep quoting half-remembered timelines from blog posts: the obligation itself sits in Articles 17 to 23 of Regulation (EU) 2022/2554 (DORA), but the exact clocks and content requirements are not in the regulation's text. They were finalized by the European Supervisory Authorities (EBA, ESMA, EIOPA) through two technical standards that the European Commission adopted as Commission Delegated Regulation (EU) 2025/301 (the RTS on content and timelines) and Commission Implementing Regulation (EU) 2025/302 (the ITS on standard forms and templates). Classification criteria, separately, come from Commission Delegated Regulation (EU) 2024/1772. If you're building a compliance program, read those three alongside the Level 1 text, not instead of it.

What makes an incident "major" in the first place

Article 18 of DORA sets the criteria; the RTS 2024/1772 turns them into thresholds with a combination rule. The logic works in two steps.

First, a gateway test: does the incident affect ICT systems supporting a critical or important function, does it affect authorised or supervised financial services, or does it involve a successful, malicious, unauthorised access to your systems. If none of these apply, you're not looking at a major incident, full stop, regardless of how bad it feels operationally.

Second, if the gateway is open, you check the materiality criteria:

An incident becomes major when the gateway is met and either there's a qualifying malicious intrusion that may cause data loss, or at least two of the materiality thresholds are triggered together. One bad number on its own, even a large economic loss, generally isn't enough by itself. This is a frequent misreading I see in incident runbooks: teams treat each criterion as independently decisive instead of applying the combination logic the RTS actually sets out. There's also an aggregation rule worth knowing: incidents with the same apparent root cause, recurring at least twice within six months, get assessed together and can collectively cross the major threshold even if each one looked fine in isolation.

What this actually requires operationally for a small EMI or PI

Most small electronic money institutions and payment institutions I work with don't have a problem understanding the rule. They have a problem executing it inside a 4-hour window with a five or ten person operations team.

A few things that genuinely move the needle:

This is exactly the operational gap Novafin's DORA incident-reporting automation work is built to close: pre-built classification logic, templated notifications, and deadline tracking that doesn't depend on one person remembering the rules under pressure. If you're also working through your third-party risk obligations, our piece on DORA Article 28 vendor registers for EMIs covers the register side of the same framework.

If you want a second pair of eyes on your incident classification and reporting setup before a real incident forces the test, reach out at team@novafin.co or through the DORA compliance page.