Contract review is a quality assurance problem

DORA, the EU Digital Operational Resilience Act, has applied since January 17, 2025 (William Fry). Article 30 sets the terms that must appear in contracts for ICT services. For a firm with hundreds of ICT contracts, checking that every one contains the right clauses is a classic quality assurance task: a defined standard, a large population of documents, sampling, findings and remediation.

QA managers in financial institutions and in ICT providers serving them are well placed to run that review.

The Article 30 standard

The Dutch Authority for the Financial Markets (AFM) summarizes the required provisions (AFM):

All ICT services contractsAdditional terms for critical or important functions
Both parties’ rights and obligationsProvider reporting obligations
Full description of the servicesImplementing and testing business contingency plans
Regions or countries where services are provided and data is processedCooperation in threat-led penetration testing (TLPT)
Service levelsRights of inspection and audit by the financial entity or an appointed third party
Data protection: availability, authenticity, integrity, confidentialityMore detailed subcontracting provisions, including accurate KPIs
Support in case of incidents
Termination rights and minimum notice periods

William Fry adds that contracts for critical or important functions also need exit strategies and unrestricted access, inspection and audit rights.

A QA method for contract review

1. Define the population

Start from the register of information, which must record every ICT services contract and flag those supporting critical or important functions. Reconcile it against procurement and legal records so nothing is missed.

2. Build the checklist

Turn each Article 30 provision into a check item with an acceptance criterion, for example: “Data processing locations named at country level.”

3. Prioritize

Review every contract supporting critical or important functions. Sample the rest, weighted by spend, data sensitivity and provider concentration.

4. Record findings consistently

For each contract: provision present, partially present or missing; clause reference; comment. Consistent findings make remediation and reporting possible.

5. Remediate and verify

Track amendments with providers and verify the updated contract, not just the promise to update.

Why the register’s quality matters more now

The European Supervisory Authorities used data from financial entities’ registers of information to designate critical ICT third-party providers, publishing the list on November 18, 2025 (EIOPA). Register data are therefore used by supervisors, not just filed. Inaccurate function flags or missing contracts are quality defects with supervisory consequences.

Who you work with

  • Legal: contract language and amendments.
  • Procurement / vendor management: contract inventory and provider relationships.
  • ICT risk: criticality assessment and security requirements.
  • Compliance: supervisory reporting and the register.
  • Internal audit: independent assurance over the process.

Common weaknesses

  • Review limited to new contracts; legacy contracts never checked.
  • Critical or important function flags inconsistent with business impact assessments.
  • Clauses present in master agreements but overridden in schedules or order forms.
  • Subcontracting terms missing for critical services.
  • Findings tracked by email, not in a controlled log.

Checklist

  • Contract population reconciled to the register of information
  • Article 30 checklist with acceptance criteria
  • All critical or important function contracts reviewed
  • Risk-based sample of other contracts reviewed
  • Findings log with remediation owners
  • Amended contracts verified

How AskDona helps

Reading hundreds of ICT contracts, including schedules and order forms, against Article 30 takes weeks. AskDona reads each contract against your Article 30 checklist, shows whether each provision is present, partly present or missing, and cites the clause and page. Run a sample DORA contract review on five contracts for critical functions. AskDona shows the evidence; your legal and compliance teams decide.

Editor’s note: Article 30 provisions are summarized from the Dutch AFM and William Fry; check the regulation and related technical standards for exact wording. Not legal advice. The LinkedIn count was supplied by the client.

FAQ

What is DORA Article 30? The article setting key contractual provisions for ICT services contracts.

Do all ICT contracts need the same terms? No. All need a base set; contracts supporting critical or important functions need additional terms.

Where should a review start? With the register of information, reconciled to contract records.

Why does register quality matter? Supervisors used register data to designate critical ICT third-party providers in November 2025.

References

All pages opened and checked by October 23, 2026.

SourceTypeUsed for
AFM: DORA third-party providersSupervisor guidanceArticle 30 provisions
William Fry: DORA management of ICT third-party riskLaw firm analysisApplication date, Article 30(3), register
EIOPA: ESAs designate critical ICT third-party providers (Nov 18, 2025)Supervisor press releaseRegister use in CTPP designation