Entry into force and application

Article 64 is the final article of DORA and establishes two fundamental legal facts: the entry into force date and the application date. DORA entered into force on January 16, 2023 — the twentieth day following its publication in the Official Journal of the European Union on December 27, 2022. It applies from January 17, 2025, meaning that from this date all in-scope financial entities and ICT third-party service providers must be fully compliant with its requirements.

The distinction between entry into force and application is significant. The entry into force date marks the point from which DORA became part of the EU legal order, while the application date is when its substantive requirements became enforceable. This two-year transition period allowed the ESAs to develop the necessary regulatory and implementing technical standards, and gave entities time to assess their compliance gaps and build the required capabilities.

The article also confirms the standard EU regulation clause that DORA is binding in its entirety and directly applicable in all Member States. Unlike directives, which require national transposition and can result in varying implementations, regulations apply uniformly and immediately. This direct applicability reinforces DORA's harmonization objectives and ensures a level playing field across the EU. From the application date, there are no further transitional arrangements — compliance is expected from day one, and competent authorities may begin supervisory assessments and enforcement actions immediately.