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Proportionality & Exemptions ​

Proportionality Principle ​

DORA takes the proportionality principle into account: requirements shall be proportionate to the size, risk profile, and complexity of financial entities.

Simplified ICT Risk Management Framework (Art. 16) ​

Microenterprises may apply a simplified ICT risk management framework. This includes:

  • Documentation of all ICT-supported business functions and associated risks
  • Protection of all ICT systems against the most common cyber threats
  • Ensuring physical security and environmental protection
  • Access control for ICT systems
  • Mechanisms for timely detection of anomalous activities
  • Business continuity measures and backup strategies
  • Review and lessons learned following ICT incidents

Exemptions by Entity Type ​

Entity SizeExemptions
Microenterprise (≤ 10 employees, ≤ EUR 2 million)Simplified risk framework (Art. 16), no TLPT; third-party risk (Chapter V) still applies in full
Art. 16 entities (specifically named in Art. 16(1))Simplified risk framework, no TLPT; eligibility is entity-type-specific, not purely size-based
Art. 16 entities (specifically named in Art. 16(1))Simplified framework, limited testing obligations
All othersFull scope

BaFin Supervisory Communication (21.08.2025) ​

BaFin has published guidance on implementing the simplified ICT risk management framework, including specific documentation requirements for eligible entities.

BAUER GROUP Classification ​

BAUER GROUP as an ICT service provider does not directly benefit from the proportionality principle, as the requirements are imposed indirectly through client contracts. However: clients subject to the simplified framework impose less demanding contractual requirements – this is addressed through tiered contract modules.

Contractual Tiering

Recommendation: Prepare two contract modules:

  1. Standard module – For microenterprises and simplified framework
  2. Premium module – For systemically important financial entities with full DORA scope

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