DORA Bounty: Auditors Are Promoted for Every Hit

Why Boards and Senior Management Should Stop Assuming “Reasonableness” Will Protect Them

There is a comforting belief at board and senior management level that auditors and supervisors arrive with a neutral mindset: fair, balanced, proportionate. That belief is dangerously incomplete.

In reality, modern regulatory audits – especially under DORA – operate under a bounty logic.
Not formally, not cynically, but structurally.

Findings are currency.
Material weaknesses are proof of relevance.
Clear hits justify scope, resources, escalation – and careers.

Understanding this is not cynical. It is essential governance literacy.

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The Myth of the Neutral Audit

Boards often assume that auditors:

• look for confirmation,
• reward good faith,
• contextualise imperfections.

DORA audits are not designed that way.

They are designed to:

• test resilience under stress,
• surface weaknesses,
• challenge governance narratives,
• and document gaps that require remediation.

An audit that finds nothing is not a success story. It is a failure of audit.

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Why DORA Creates a “Bounty” Environment

DORA Is New, Broad and Politically Charged

DORA is:

• pan-European,
• high-profile,
• and explicitly designed to raise supervisory intensity.

Auditors are expected to demonstrate:

• rigour,
• consistency,
• and impact.

In such an environment, findings are not accidents. They are outcomes.

Governance Gaps Are Easier to Hit Than Technical Ones

Boards often believe technical robustness will carry them through. Auditors know better.

They target:

• unclear accountability,
• missing decision records,
• unarticulated risk appetite,
• silent acceptance of weaknesses.

These are clean hits. And they sit squarely with senior management and the board.

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What Boards Misunderstand About “Reasonableness”

A common defence sounds like this:

“Given our size and complexity, this was reasonable.”

Auditors will respond — implicitly or explicitly:

“Reasonable compared to what you documented and decided.”

Under DORA, reasonableness without evidence is irrelevant.

If the board did not:

• define tolerances,
• prioritise explicitly,
• accept risks consciously,

then the organisation did not act reasonably.
It acted silently.

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The Personal Dimension Boards Prefer to Ignore

Audit findings do not stay abstract.

They trigger:

• remediation programmes,
• follow-up audits,
• management attention,
• and supervisory memory.

Each finding becomes a reference point:

“This was already identified.”

Boards should understand: Findings compound. They do not expire quietly.

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How Auditors Will Frame the Hits

Auditors will not say:

• “You failed.”

They will say:

• “The governance framework does not ensure…”
• “The management body cannot demonstrate…”
• “Decision-making is not sufficiently evidenced…”

These phrases are surgical. They land exactly where accountability resides.

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How Boards Can Reduce Exposure Without Playing Defence

This is not about arguing with auditors. That battle is already lost.

It is about removing easy targets.

Force Decisions, Even Uncomfortable Ones

Undecided topics are auditor magnets.

Boards must force clarity on:

• critical functions,
• acceptable downtime,
• tolerated dependencies.

Ambiguity is an open invitation.

Document Risk Acceptance Explicitly

If a weakness exists:

• either fix it,
• or accept it — in writing.

Silence will be interpreted as ignorance, not prudence.

Make DORA a Standing Governance Topic

If DORA appears only episodically in board materials, auditors will assume:

• lack of ownership,
• lack of priority,
• lack of control.

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The Hard Truth About the “Bounty”

Auditors are not villains. They are doing exactly what the system rewards.

Boards that understand this shift from asking:

“Are we compliant?”

to asking:

“Where are we easiest to hit — and why?”

That question is uncomfortable. It is also the beginning of real operational resilience.

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Final Thought

DORA does not introduce a bounty system. It reveals one that has always existed.

Boards and senior management who continue to rely on good intentions, informal oversight and assumed reasonableness will provide auditors with easy hits.

Those who govern decisively, document consciously and accept risk openly will not avoid findings entirely – but they will avoid the ones that matter most.

In the DORA era, governance is no longer about appearing reasonable. It is about being provably deliberate.