Article 4Proportionality principle
1. Financial entities shall implement the rules laid down in Chapter II in accordance with the principle of proportionality, taking into account their size and overall risk profile, and the nature, scale and complexity of their services, activities and operations.
2. In addition, the application by financial entities of Chapters III, IV and V, Section I, shall be proportionate to their size and overall risk profile, and to the nature, scale and complexity of their services, activities and operations, as specifically provided for in the relevant rules of those Chapters.
3. The competent authorities shall consider the application of the proportionality principle by financial entities when reviewing the consistency of the ICT risk management framework on the basis of the reports submitted upon the request of competent authorities pursuant to Article 6(5) and Article 16(2).
DORA, the European Union regulation on digital operational resilience, Article 4
Proportionality, and the article is narrower than the word suggests. The whole of Chapter II, the ICT risk management rules, is to be applied in proportion to the entity’s size and overall risk profile and to the nature, scale and complexity of its services, activities and operations. For incident management (Chapter III), testing (Chapter IV) and the key principles on third-party risk (Chapter V, Section I), proportionality applies too, but only as those chapters specifically provide.
Competent authorities must take that into account when they review an entity’s ICT risk management framework, using the review reports they can request under Articles 6(5) and 16(2).
The article tells entities to apply the rules in proportion; it does not itself excuse any duty. The lighter treatment the Regulation gives is written into particular articles: reduced duties for microenterprises, the simplified framework in Article 16, and threat-led testing only for entities that authorities identify under Article 26.
The detail on how to judge increased or reduced complexity is in the regulatory technical standards under Articles 15 and 16(3), Commission Delegated Regulation (EU) 2024/1774. Check the current text for amendments.
What is in the packs for this
From DORA ICT Risk & Resilience Readiness. Each one helps with this requirement.
DORA Proportionality & Scope AssessmentExcel
The whole workbook sets what kind of entity you are, so that the depth of each duty follows size, risk and complexity.
DORA Article-to-Control Mapping LibraryExcel
Requirement Library rows RQ-02: each gives the provision in plain words, what an entity must be able to show and the documents that help.
DORA Readiness Self-AssessmentExcel
Readiness items SC-01 rate how ready the entity is for the provision, with the evidence behind each rating and the gap.
ICT Risk Management Framework Document TemplateWord
Scope and proportionality section: the proportionality log (FW-03).
DORA Documentation & Evidence ChecklistExcel
Evidence records EV-01: the records a supervisor can ask for under the provision, with who keeps them and for how long.
Text: Regulation (EU) 2022/2554, as published in the Official Journal of the European Union, from EUR-Lex. Only the Official Journal text is authentic.