Technical Debt: The Ticking Time Bomb in Your DORA Compliance Strategy

Technical Debt: The Ticking Time Bomb in Your DORA Compliance Strategy

For decades, technical debt has been the silent risk accumulating in financial institutions. It was the necessary evil of innovation. But in 2026, one year into DORA, that silent risk is now a ticking time bomb.

DORA has fundamentally redefined technical debt, transforming it from an IT concern into a board-level regulatory issue. Legacy systems are simply not fit for the new era of demonstrable resilience.

💣 WHY LEGACY SYSTEMS ARE A DORA FAILURE WAITING TO HAPPEN

DORA's requirements for a comprehensive ICT risk management framework¹ challenge most legacy environments. These systems are poorly documented with unknown dependencies, making it nearly impossible to meet requirements for:

• Identification (Article 10): You can't manage what you can't see. Identifying all assets and dependencies in a decades-old mainframe system is a monumental task.
• Protection (Article 11): Legacy systems are riddled with unpatched vulnerabilities and outdated security controls, making them an easy target for attackers.
• Resilience Testing (Article 24): DORA mandates advanced testing like Threat-Led Penetration Testing (TLPT). Most firms wouldn't dare run a full-scope TLPT on their core banking system for fear of causing a catastrophic failure.

This isn't just a theoretical problem. The ECB's supervisory priorities for 2026-28² make it clear that the oversight of critical third-party providers is a key focus. This scrutiny will inevitably extend to the legacy systems that connect to them.

📉 THE RISING COST OF INACTION

The cost of maintaining these aging systems is spiraling, while the workforce familiar with them is retiring³. At the same time, they are incapable of supporting the new demands of AI, open banking APIs, and continuous regulatory reporting⁴.

This creates a dangerous paradox: the most critical systems are also the most resistant to change and the most vulnerable to attack.

❓ THE CRITICAL QUESTION FOR 2026

The era of kicking the can down the road on legacy modernization is over. The management body is now explicitly responsible for managing all ICT risks⁵, including technical debt.

The critical question for your board in 2026 is: is your technical debt a manageable part of your ICT strategy, or is it a systemic risk to your operational resilience and a direct threat to your DORA compliance?

References

¹ Regulation (EU) 2022/2554 (DORA), Article 6 ² ECB Banking Supervision, Supervisory Priorities 2026-28 ³ ABA Banking Journal, "Off the map: Top bank risks for 2026" (Jan 2026) ⁴ Fintech Global, "Can continuous reporting replace the legacy regulatory pipeline?" (Jan 2026) ⁵ DORA, Article 8