Pillar I: ICT Risk Management Framework
10

Chapter II — ICT risk management

Section III — Detection

Detection

detectionmonitoringanomaly-detectionsingle-point-of-failure

Summary

Requires financial entities to establish mechanisms to promptly detect anomalous activities, including network performance issues, ICT-related incidents, and potential single points of failure. Detection capabilities must be tested regularly as part of the resilience testing programme.

Key Requirements

  1. 1

    Deploy mechanisms for prompt detection of anomalous activities

  2. 2

    Monitor network performance and ICT-related incidents continuously

  3. 3

    Identify potential single points of failure

  4. 4

    Implement multi-layer detection controls

  5. 5

    Test detection capabilities regularly

Detailed Analysis

Article 10 addresses the detection pillar of the NIST-aligned framework that DORA implicitly follows (Identify, Protect, Detect, Respond, Recover). Without effective detection, even the best protection measures are insufficient because threats that evade prevention go unnoticed until significant damage occurs.

Financial entities must implement mechanisms capable of promptly detecting anomalous activities at multiple levels — network, application, data, and user behavior. These mechanisms should cover both automated detection (SIEM, IDS/IPS, behavioral analytics) and human-driven monitoring (SOC operations, threat hunting). The goal is to minimize the dwell time between an intrusion or failure and its detection.

Single points of failure represent a particular concern. The article requires entities to proactively identify components whose failure would cause disproportionate disruption — whether a critical database without replication, a network link without redundancy, or a key person without backup. Once identified, these single points must be addressed through redundancy, failover, or documented risk acceptance.

Detection capabilities must not be static. The article requires regular testing to ensure that monitoring systems remain effective as the ICT environment evolves. New applications, infrastructure changes, and emerging threat tactics can all create blind spots in detection coverage that must be identified and remediated through continuous validation.

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