
Does DORA require a permanently employed CISO?
Under Article 6(4) DORA, financial entities other than microenterprises and outside the simplified framework need a control function for ICT risk with an appropriate level of independence. BaFin calls it the ICT risk control function. DORA mentions neither a CISO nor any form of employment. Whether an external CISO can perform the function depends on the mandate, on independence and on the outsourcing rules of MaRisk or MaGo.












