Beyond Compliance: Architecting Digital Resilience for DORA with ServiceNow CSDM

Introduction

The Digital Operational Resilience Act (DORA) presents substantial challenges for European financial institutions, requiring a robust framework for managing ICT third-party risk, incident response, and operational resilience. While DORA mandates specific compliance requirements, its true value lies not merely in checking regulatory boxes, but in cultivating genuine operational resilience that inherently satisfies those mandates. 

For enterprise architects, this means building a robust, transparent, and interconnected operational foundation. Achieving such resilience requires not only the structured data foundation provided by ServiceNow’s Common Service Data Model (CSDM) but also a mindset that treats compliance as a strategic imperative rather than an administrative obligation.

The Common Service Data Model (CSDM) 5.0 builds upon its foundational principles to provide a more comprehensive and prescriptive reference for mapping business and IT services within the ServiceNow AI Platform. It expands beyond traditional technology workflows to support business digital transformation and establish a Digital Value Network. This makes CSDM 5.0 an essential framework for achieving and demonstrating compliance, including with regulations like the Digital Operational Resilience Act (DORA).This paper outlines how leveraging CSDM 5.0 within the ServiceNow ecosystem can empower financial institutions to not only meet DORA’s stringent requirements but also transform compliance into a strategic advantage for enhanced operational resilience. Financial institutions frequently contend with complex and siloed data environments. This fragmentation can make it difficult to gain clear insights into service dependencies and provider relationships, hindering efforts to meet comprehensive regulatory demands like those found in DORA, but in any regulatory body. This underscores the need for a unified, holistic approach to operational data, establishing a reliable source of truth. CSDM is designed to address this need by providing a standardized framework.

The Digital Operational Resilience Act (DORA): Key Challenges

DORA aims to harmonize and strengthen ICT risk management across the European financial sector. Its core pillars impose significant obligations on financial entities, including:

• ICT Risk Management Frameworks: Establishing and maintaining robust ICT risk management frameworks.
• ICT-Related Incident Management, Classification, and Reporting: Implementing comprehensive processes for managing, classifying, and reporting ICT-related incidents.
• Digital Operational Resilience Testing: Conducting regular and thorough digital operational resilience testing.
• Managing ICT Third-Party Risk: Addressing risks arising from reliance on third-party ICT service providers.
• Information Sharing: Facilitating the sharing of cyber threat information.

For many financial institutions, a primary challenge lies in gaining a holistic, real-time understanding of their critical functions, the underlying ICT assets supporting them, and the intricate web of dependencies, especially those involving third-party providers. Without a standardized data model, this visibility remains fragmented, hindering effective incident response, risk assessment, and compliance reporting. The ultimate goal is to move beyond mere compliance to a state where robust operational resilience is an intrinsic part of the organization’s digital fabric.

Understanding the Common Service Data Model (CSDM) 5.0 Framework in the Context of DORA

CSDM is ServiceNow’s standardized data model that defines service-related data and relationships across the platform. It offers prescriptive guidance for modeling data using out-of-the-box tables, relationships, and references, enabling powerful cross-product use cases.

Key CSDM 5.0 components relevant to DORA:

• Ideation & Strategy Domain: The initial stage of the CSDM Lifecycle. This domain captures the strategic planning and conceptualization of new services and improvements, ensuring that operational resilience considerations are embedded from the earliest stages of service design. This allows financial institutions to model and assess the resilience of new digital products and services from their inception, aligning with DORA’s emphasis on proactive risk management and resilience-by-design.
• Foundation Domain: Provides foundational data (e.g., Company, Location, Groups, Product Models) that supports all other domains. This ensures a consistent and reliable base for all operational and compliance activities.

• Design & Planning Domain (Enterprise Architecture – EA): Focuses on logical design elements like Business Capabilities and Business Applications. This domain is crucial for Enterprise Architecture, enabling the comprehensive modeling and visualization of the enterprise’s technology landscape. By understanding the current and target state architectures, EA provides the clarity needed to identify resilience gaps, optimize technology investments, and inform strategic prioritization of initiatives that underpin critical business functions.
• Build & Integration Domain: Provides visibility into the development and integration efforts of digital products, including DevOps processes. This ensures that resilience is built into the development lifecycle.
• Service Delivery Domain: Represents the operational view of deployed services and their underlying infrastructure (e.g., Service Instances, APIs, Hosts). This domain is key for proper service management practices, ensuring services are delivered reliably and efficiently.
• Service Consumption Domain: Identifies business services consumed by users and their related offerings. This provides insights into the actual utilization and value of services.
• Manage Portfolio Domain: Encompasses oversight across multiple domains, providing a holistic view for service owners. This domain is central to Strategic Portfolio Management, facilitating not just roadmap and project management, but also robust resource and capacity management. SPM enables the prioritization of initiatives based on strategic goals, DORA compliance needs, and business value, and supports informed trade-off decisions when resources are constrained. By connecting strategy (from Ideation & Strategy) to execution, SPM ensures that investments are aligned with the organization’s most critical resilience objectives.
• Product Modeling and Software Bill of Materials (SBOM). SBOM provides a detailed inventory of all components within a piece of software, which is critical for tracking potential vulnerabilities and managing ICT third-party risk. This directly supports DORA’s requirements for identifying and managing risks associated with ICT third-party providers and their supply chains, enabling better visibility into software dependencies and potential weaknesses.
• Service Instances: The concept of Service Instance with sibling classes such as Data Service Instance, Connection Service Instance, Network Service Instance, Operational Process Service Instance, and Facility Service Instance provides a granular and accurate way to model the various components and layers of digital services, which is crucial for detailed impact analysis, incident response, and understanding interdependencies as required by DORA. It allows for a more precise mapping of critical functions to their underlying ICT assets.

Leveraging CSDM 5.0 and ServiceNow for DORA Compliance and True Operational Resilience

Achieving compliance with the Digital Operational Resilience Act (DORA) and fostering a state of true operational resilience requires a structured data foundation and a strategic architectural approach. CSDM 5.0, particularly when implemented within a platform like ServiceNow, provides the necessary framework to meet DORA’s stringent requirements. By combining robust data modeling with targeted actions, financial institutions can build inherent resilience across their operations.

1. Foundational Visibility: Mapping Critical Functions and Managing ICT Assets

DORA mandates a clear understanding of critical business functions and their supporting ICT infrastructure. CSDM 5.0 facilitates this by enabling accurate modeling of Business Services, their underlying Service Instances (including the expanded Data, Network, Operational Process, and Facility Service Instances), and ICT assets. This foundational visibility is crucial for identifying and classifying critical ICT-related services.

To achieve this, a phased approach can be adopted: 

* Discover and Inventory: Utilize ServiceNow Discovery and Service Mapping to automatically populate the Configuration Management Database (CMDB) with ICT assets and their relationships. This forms the foundational layer of CSDM, providing essential asset visibility. 

* Model Critical Services and Architecture (EA): Define Business Services and Service Offerings, as well as the expanded Service Instances to accurately represent critical business functions and their technical underpinnings. Concurrently, leverage Enterprise Architecture (EA) tools to model and visualize current and target state architectures, ensuring a clear understanding of dependencies and resilience requirements. This architectural clarity is vital for mapping resilience across the entire service chain. 

* Map Dependencies: Establish clear relationships between Business Services, Service Instances, and underlying ICT components, including third-party services, leveraging CSDM’s prescribed relationships. This is critical for proper service management practices and understanding interdependencies.

CSDM’s robust CMDB and expanded Product Modeling, including the Software Bill of Materials (SBOM), enable a detailed and accurate inventory of all ICT assets, configurations, and software components. This comprehensive asset management capability moves beyond simple inventory to provide actionable insights, crucial for proactive risk assessment, vulnerability management, and understanding the operational state of every component.

2. Enhancing Incident Management and Third-Party Risk

Clear service dependencies established through CSDM are paramount for effective incident management. When ICT incidents occur, their impact can be rapidly identified and assessed, facilitating timely classification, escalation, and reporting, aligning with DORA’s incident management and reporting obligations. 

* Automate Incident Response: Configure automated workflows within ServiceNow for incident detection, classification, and response based on CSDM-defined service impacts. This streamlines service management practices for rapid recovery.

Furthermore, CSDM 5.0 enhances third-party risk management. SBOM and detailed Service Instance modeling allow for granular visibility into ICT third-party dependencies. 

* Implement Risk and Vulnerability Management: Integrate SBOM data to identify software vulnerabilities and leverage ServiceNow’s risk management capabilities to assess and mitigate ICT-related risks. This enables financial institutions to better understand and manage risks associated with their supply chain, allowing Strategic Portfolio Management (SPM) to prioritize initiatives for mitigating these identified risks and ensuring third-party resilience is actively managed.

3. Proactive Resilience Testing and Strategic Prioritization

A well-defined CSDM, informed by EA’s architectural insights, supports proactive operational resilience testing. It allows for the simulation of disruptions and testing of resilience capabilities against specific critical services and their underlying components. This provides actionable insights for DORA’s testing requirements, demonstrating actual resilience rather than theoretical compliance.

To ensure these resilience efforts are effective and aligned with broader business objectives: 

* Strategic Prioritization and Resource Management (SPM): Employ Strategic Portfolio Management (SPM) to prioritize DORA compliance initiatives within the overall portfolio. This involves optimizing resource allocation, managing capacity, and making informed trade-off decisions based on architectural insights and DORA requirements. By leveraging CSDM data, SPM ensures that critical resilience projects receive the necessary investment and attention, embedding resilience into the strategic fabric of the organization.

4. Enabling Continuous Monitoring and Reporting

Finally, to maintain ongoing compliance and resilience, continuous oversight is essential. 

* Enable Continuous Monitoring and Reporting: Utilize ServiceNow dashboards and reporting capabilities to continuously monitor operational resilience metrics, track compliance status, and generate DORA-required reports. These reports should incorporate insights from both EA (architectural integrity) and SPM (strategic execution) to provide a holistic view of the institution’s resilience posture.

By systematically leveraging CSDM 5.0 within a platform like ServiceNow, financial institutions can move beyond mere compliance to build a truly resilient operational environment, capable of withstanding and rapidly recovering from ICT disruptions.

Infocenter RADIUS Engagement: Architecting Your DORA Compliance Roadmap with ServiceNow

Engagement Overview:

The RADIUS (Resilience Architecture & DORA Implementation Strategy) engagement is a strategic workshop series designed to accelerate your organization’s journey towards DORA compliance using the ServiceNow platform. Building upon the understanding that DORA requires more than just a checklist approach, RADIUS focuses on establishing a robust, data-driven foundation for sustainable operational resilience.

The main result is a clear and actionable plan that outlines the minimum CSDM structure and ServiceNow configuration improvements needed for accurate, efficient, and compliant DORA regulatory reporting, as well as the development of true operational resilience.

This RADIUS engagement provides the clarity and direction needed to leverage ServiceNow effectively, transforming DORA compliance from a regulatory burden into a strategic advantage in operational resilience.

Conclusion

DORA should be seen as a catalyst for architectural improvement. By strategically implementing ServiceNow CSDM as the foundation, leveraging the integrated capabilities of the Now Platform—including Strategic Portfolio Management for aligning efforts and Enterprise Architecture for managing technology complexity—organizations can move beyond reactive compliance efforts. They can build a unified, transparent, and resilient operating model that not only satisfies regulatory demands but also provides a lasting foundation for navigating future disruptions and driving business value.

Navigating the complexities of DORA requires more than just a checklist; it demands a deep understanding of operational interdependencies and a commitment to building a resilient foundation. Through a structured engagement process, financial institutions can transform DORA compliance from a regulatory burden into a strategic opportunity. Leveraging insights gained from collaborative workshops, organizations can establish a robust CSDM foundation, align SPM initiatives, implement EA governance, and configure key ServiceNow modules. This approach ensures that DORA compliance efforts not only meet regulatory requirements but also cultivate sustainable operational resilience, positioning organizations for enduring success in an increasingly complex digital landscape.