Article 9: Protection and prevention

To meet the article 9: protection and prevention requirement, you must continuously monitor and control the security and functioning of your ICT systems and tools, and reduce ICT risk impact through appropriate security tools, policies, and procedures. Operationalize it by defining scope, assigning accountable owners, implementing monitoring and preventive controls, and keeping audit-ready evidence that the controls run and exceptions get fixed. (Regulation (EU) 2022/2554, Article 9)

Key takeaways:

• “Continuously monitor and control” requires always-on detection plus defined control actions, not periodic reviews. (Regulation (EU) 2022/2554, Article 9)
• Supervisors will test operation, not intent: show logs, tickets, tuning, and closed remediation, tied to system criticality.
• Build a single traceable register from Article 9 to controls, owners, and evidence, so exams don’t turn into document hunts.

Article 9 is the “keep the lights on safely” requirement in DORA: you need ongoing visibility into ICT security and performance, plus preventive safeguards that reduce the impact of ICT risk. The operative words are “continuously” and “minimise the impact.” If you cannot show that monitoring runs without gaps, that alerts lead to action, and that preventive controls exist and are maintained, you will struggle in an examination. (Regulation (EU) 2022/2554, Article 9)

For a Compliance Officer, CCO, or GRC lead, the fastest path is to translate Article 9 into a small set of auditable control outcomes: (1) you know what systems and tools are in scope, (2) you have defined monitoring coverage and thresholds, (3) you have protective baselines and hardening expectations, (4) you manage exceptions and remediate findings, and (5) you can produce evidence on demand. This page focuses on requirement-level implementation guidance you can assign to security operations, IT operations, and control owners, while keeping compliance in a coordinating role that ensures traceability and evidence discipline. (Regulation (EU) 2022/2554, Article 9)

Regulatory text

DORA Article 9(1) requires that financial entities:

• continuously monitor and control the security and functioning of ICT systems and tools; and
• minimise the impact of ICT risk on ICT systems through appropriate ICT security tools, policies and procedures. (Regulation (EU) 2022/2554, Article 9)

Operator interpretation (what you must be able to prove):

1. Monitoring is ongoing and covers the systems/tools that matter to delivering regulated services.
2. Monitoring produces actionable outputs (alerts, events, performance indicators) and those outputs lead to defined control actions (triage, containment, recovery steps, problem management).
3. Preventive controls exist, are appropriate to risk, and are maintained (patched, tuned, reviewed, enforced).
4. You can show governance: ownership, documented procedures, and records of operation and remediation. (Regulation (EU) 2022/2554, Article 9)

Plain-English interpretation of the requirement

Article 9 is a mandate for operational security and resilience hygiene:

• “Monitor” means detect security and availability issues as they happen, not after the fact.
• “Control” means you don’t just observe; you have mechanisms to prevent, limit, and correct issues (automated blocking, configuration enforcement, access controls, incident runbooks, change gates).
• “Minimise impact” means you design and operate controls so incidents and failures cause less harm: fewer systems affected, shorter disruption, lower data exposure, and faster recovery. (Regulation (EU) 2022/2554, Article 9)

This is not a paperwork-only requirement. Policies matter, but only as far as they drive consistent operational behavior and measurable coverage.

Who it applies to (entity and operational context)

Applies to: financial entities in scope of DORA. (Regulation (EU) 2022/2554, Article 9)

Operational scope (what supervisors will treat as in-scope):

• Production ICT systems supporting critical or important functions (customer-facing channels, trading, payments, core banking/ledger, claims processing).
• Supporting systems that can materially affect those services (identity, endpoint fleet, network, backups, monitoring stack, CI/CD, key management).
• ICT tools used to secure and operate those systems (SIEM/logging, EDR, vulnerability management, IAM/PAM, configuration management, patching tooling). (Regulation (EU) 2022/2554, Article 9)

Third parties: Article 9 is directed at the financial entity, but if monitoring or controls are provided by third parties (managed SOC, cloud provider controls, MSSP tooling), you still need visibility and evidence that the control operates for your environment.

What you actually need to do (step-by-step)

Use this sequence to operationalize quickly and avoid “we have tools” arguments that fail under scrutiny.

1) Define scope and criticality

• Build an inventory of ICT systems and tools, and tag which support critical or important functions.
• Define “minimum monitoring coverage” by criticality (what must be logged, what must be alerted, and what must be measured for performance/availability).
• Document system ownership (business owner, IT owner, security owner) and the escalation path. (Regulation (EU) 2022/2554, Article 9)

Deliverable: Article 9 scope statement + in-scope system list with owners.

2) Map Article 9 to concrete controls and evidence (single register)

Create a register that ties:

• requirement statement → control objective → control owner → tooling/process → evidence location.

This is the fastest way to prevent exam chaos. The evidence location matters (link to SIEM dashboard, ticket queue, patch reports repository, change records). Your goal is “one click to proof.”

If you use Daydream, implement this as a living requirement-to-control map with assigned owners and an evidence checklist per control, so control operation is documented as part of normal work, not a quarterly scramble.

3) Implement “continuous monitoring” for security and functioning

Minimum expectations to operationalize “continuous”:

• Centralized logging for key systems, with defined log sources and retention aligned to your internal risk decisions.
• Alerting rules for high-impact conditions (authentication anomalies, privileged activity, malware detections, service health degradations, backup failures).
• On-call or monitored queue with documented triage steps and escalation time expectations set internally. (Regulation (EU) 2022/2554, Article 9)

Control action requirement: For each alert class, define what “control” means (block, isolate host, disable credential, failover, rollback change, open problem record).

4) Deploy preventive safeguards to minimise impact

Translate “tools, policies and procedures” into enforceable baselines:

• Access controls: MFA where feasible, PAM for privileged accounts, joiners/movers/leavers procedures.
• Endpoint/network protections: EDR, network segmentation principles, secure remote access configuration.
• Vulnerability and patching: asset discovery, scanning cadence you set, patch SLAs you set, exception process with risk acceptance.
• Secure configuration: hardened images, configuration drift detection, change control gates for high-risk changes.
• Resilience mechanisms: backups with restore testing, capacity/performance monitoring, high availability where risk justifies it. (Regulation (EU) 2022/2554, Article 9)

You do not need every control to be perfect on day one. You do need a risk-based rationale, compensating controls where gaps exist, and a tracked remediation plan.

5) Operationalize response measures (tie monitoring to incident/problem management)

Article 9 explicitly connects monitoring to “organising response measures.” (Regulation (EU) 2022/2554, Article 9)

Implement:

• A single intake path for security and availability events (SIEM/SOC queue + ITSM incident queue, with a routing rule).
• Severity taxonomy that determines who is paged and who must be informed (security, IT ops, business).
• Post-incident actions: root cause analysis, corrective actions, validation evidence, closure approval.

6) Prove control operation through routine testing and remediation discipline

Build a cadence that generates evidence naturally:

• Monitoring health checks (are agents reporting, are log sources connected, are alerts firing as expected).
• Tabletop or operational drills (alert-to-ticket, escalation, containment steps).
• Remediation tracking with due dates, exceptions, and closure evidence (screenshots, reports, change records, retest results). (Regulation (EU) 2022/2554, Article 9)

Required evidence and artifacts to retain

Keep evidence tied to systems, owners, and time periods. Auditors will ask for samples.

Governance and scope

• Article 9 control register (requirement → control → owner → evidence pointer).
• In-scope ICT inventory with criticality and ownership.
• Policies/procedures supporting monitoring, hardening, patching, access, incident handling. (Regulation (EU) 2022/2554, Article 9)

Operational monitoring

• SIEM/logging coverage list (log sources, onboarding dates, current status).
• Alert catalogue with thresholds, runbooks, and escalation rules.
• Monitoring dashboards for availability/performance and evidence of review (tickets, shift logs). (Regulation (EU) 2022/2554, Article 9)

Preventive controls

• Patch/vulnerability reports, exception approvals, remediation tickets.
• Configuration baseline standards and drift reports.
• IAM/PAM access reviews, privileged session logs where applicable. (Regulation (EU) 2022/2554, Article 9)

Response measures and remediation

• Incident records linking detection → containment → recovery → lessons learned.
• Problem management/root cause analysis records.
• Corrective action plans with validation evidence and closure sign-off.

Common exam/audit questions and hangups

Expect these lines of questioning:

1. “Show me continuous monitoring.” Provide a list of monitored assets, log sources, and recent alerts with associated tickets and outcomes. (Regulation (EU) 2022/2554, Article 9)
2. “What happens when monitoring fails?” Demonstrate health checks for agents/log pipelines and how gaps are detected and fixed.
3. “How do you minimise impact?” Show hardening standards, patch workflow, segmentation decisions, backup/restore evidence, and documented exceptions. (Regulation (EU) 2022/2554, Article 9)
4. “Who owns this?” Auditors dislike “shared responsibility” without a named accountable owner and escalation route.
5. “Prove closure.” Findings without closure evidence read as ineffective control operation.

Frequent implementation mistakes and how to avoid them

Mistake	Why it fails	How to avoid it
Treating “continuous” as a monthly report	“Continuous” implies ongoing operational monitoring, not periodic governance review. (Regulation (EU) 2022/2554, Article 9)	Define monitoring uptime expectations, pipeline health checks, and on-call procedures.
Owning tools but not outcomes	A SIEM/EDR purchase is not control operation.	Tie alerts to tickets, require disposition codes, and review metrics for missed/false alerts.
Fragmented evidence	Evidence scattered across teams leads to missed deadlines and inconsistent answers.	Maintain one Article 9 control register with evidence pointers and owners.
Weak exception handling	Untracked exceptions become permanent gaps.	Require risk acceptance with expiry, compensating controls, and re-approval triggers.
Monitoring without response measures	Article 9 links monitoring to organized response. (Regulation (EU) 2022/2554, Article 9)	Maintain runbooks, escalation matrices, and drill the workflow.

Enforcement context and risk implications

No public enforcement cases were provided in the supplied sources, so this page does not list specific actions or penalties.

Practical risk: Article 9 failures tend to surface during incident response (you missed detection) and during operational outages (you lacked functioning monitoring and control). The supervisory impact is usually broader than the single gap because it raises questions about governance, operational discipline, and the reliability of reporting. (Regulation (EU) 2022/2554, Article 9)

Practical 30/60/90-day execution plan

Use this as an execution sequence. Adjust depth based on entity size and complexity.

First 30 days (stabilize scope and accountability)

• Confirm in-scope systems/tools and assign accountable owners.
• Stand up the Article 9 requirement-to-control-to-evidence register.
• Identify top monitoring gaps: missing logs, unmonitored critical services, no alert runbooks.
• Define escalation path and ticketing workflow for security and service issues. (Regulation (EU) 2022/2554, Article 9)

By 60 days (operate and evidence)

• Onboard priority log sources and establish monitoring health checks.
• Publish alert catalogue and runbooks for high-impact scenarios.
• Implement or tighten vulnerability/patch exception workflow with approvals and expiry.
• Run at least one readiness drill (alert → ticket → escalation → closure) and document corrective actions. (Regulation (EU) 2022/2554, Article 9)

By 90 days (prove minimised impact, not just visibility)

• Expand monitoring coverage to remaining high-risk systems and key third-party-supported services.
• Formalize configuration baselines and drift reporting for critical platforms.
• Demonstrate remediation discipline: closed tickets with validation evidence, trend reporting for recurring issues.
• Package an “exam-ready” evidence set: sample alerts, incident records, patch reports, exception approvals, and the control register. (Regulation (EU) 2022/2554, Article 9)

Frequently Asked Questions

Does “continuously monitor” require 24/7 SOC coverage?

DORA Article 9 requires continuous monitoring and control, but it does not prescribe a staffing model in the excerpt provided. Set coverage and escalation expectations based on system criticality, then document and evidence how monitoring outputs get acted on. (Regulation (EU) 2022/2554, Article 9)

What counts as “ICT systems and tools” for Article 9 scope?

Treat production systems that deliver regulated services as in scope, along with the security/operations tooling that monitors and protects them. Document your scoping logic and owners so you can defend why something is included or excluded. (Regulation (EU) 2022/2554, Article 9)

Can we satisfy Article 9 with policies alone?

No. Article 9 explicitly calls for continuous monitoring and control and reducing impact through tools, policies, and procedures. Supervisors typically expect operational records that show the controls run and exceptions are handled. (Regulation (EU) 2022/2554, Article 9)

How do we prove we “minimise the impact” of ICT risk?

Show preventive controls (patching, hardening, IAM) plus evidence they are maintained, and show response measures (runbooks, incident records, corrective actions) that reduce recurrence. Pair each claim with artifacts from systems and tickets, not slideware. (Regulation (EU) 2022/2554, Article 9)

How should we handle monitoring and security controls provided by third parties?

Keep contractual and operational visibility into what the third party monitors, what alerts you receive, and how issues are escalated and remediated. Store third-party reports and tickets alongside your internal evidence so your Article 9 story remains end-to-end. (Regulation (EU) 2022/2554, Article 9)

What is the single fastest way to get exam-ready for Article 9?

Build a single register that maps Article 9 to controls, owners, and evidence pointers, then run a short drill to prove you can retrieve evidence and show closure. Daydream can streamline this by turning the mapping and evidence checklist into an owned workflow rather than an offline spreadsheet. (Regulation (EU) 2022/2554, Article 9)