The majority of European financial institutions believe that failure to adopt AI and digital tools will undermine their competitiveness within five years, yet most remain unprepared to meet the requirements of the EU’s Digital Operational Resilience Act (Dora), according to PwC Luxembourg.
The report has shown that 84% of financial firms see AI and digital transformation as essential to their future success. However, only 4% have integrated Dora requirements into their day-to-day operations, while 65% are still in the early stages of assessing what needs to be done. Rather than treating Dora as a compliance obligation, many institutions are beginning to view it as an opportunity to modernise core operational processes and build long-term digital resilience.
The findings are based on a March 2025 survey of financial institutions across the European Economic Area, including banks, insurers, asset managers and payment firms.12% of respondents reported having a sound and well-designed data management strategy, a foundational element for both AI adoption and Dora compliance. Meanwhile, 55% are still working to define their critical information and communications technology (ICT) functions and information assets, a key step required under the new regulation.
Dora’s complex implications for asset managers
The report also highlighted expectations around the benefits of AI, with 49% of firms predicting it will cut organisational costs by 10% or more. However, according to the researchers, without robust data governance and operational resilience structures in place, the full potential of AI is unlikely to be realised.
While 86% of respondents have implemented ICT risk taxonomies (structured lists that categorise tech-related risks to help firms identify and manage them), only 39% have developed a methodology to quantify those risks. Some 58% of firms believe their third-party providers still face significant compliance gaps, and 26% anticipate terminating at least one ICT provider this year due to Dora-related shortcomings.
Olivier Carré, deputy managing partner, technology & transformation leader at PwC Luxembourg, commented: “Dora is a catalyst for well-calibrated reinvention. We are seeing a growing number of financial institutions moving fast to use AI and risk quantification as tools to reduce costs and build smarter, resilient businesses. Dora is the lynchpin that undergirds this transformation.”
Michael Horvath, sustainability and sustainable finance leader at PwC Luxembourg, added: “This report confirms that Dora is a foundational pillar of the digital transformation. The firms leading the way aren’t just complying, they are using the momentum generated by the regulation to embed resilience into corporate strategies and create new forms of value across the entire ecosystem. Those who fail to see Dora’s transformative potential, particularly ICT third-party providers, risk falling by the wayside. There is no time to waste.”











