Article 13: Learning and evolving

To meet the Article 13: learning and evolving requirement, you must staff and operate an ongoing capability to collect information about vulnerabilities, cyber threats, and ICT-related incidents, then assess their likely impact on your digital operational resilience and drive measurable remediation. Treat it as a repeatable operational loop, not a one-time assessment. (Regulation (EU) 2022/2554, Article 13)

Key takeaways:

• Stand up a defined “intake → analysis → action → evidence” workflow for threats, vulnerabilities, and incidents. (Regulation (EU) 2022/2554, Article 13)
• Assign accountable owners and ensure you have sufficient skills and staffing to run the loop continuously. (Regulation (EU) 2022/2554, Article 13)
• Retain traceable evidence that analysis led to prioritization, decisions, and closed remediation across systems and third parties. (Regulation (EU) 2022/2554, Article 13)

Article 13 is a learning requirement with operational teeth: regulators expect you to show that your organization continuously gathers intelligence on vulnerabilities, cyber threats, and ICT-related incidents, analyzes what that intelligence means for your resilience, and translates it into action. The control objective is not “we subscribe to a threat feed” or “we run a scanner.” The objective is a staffed, repeatable capability that connects signals to impact analysis and then to remediation, risk decisions, and improved controls. (Regulation (EU) 2022/2554, Article 13)

For a CCO or GRC lead, the fastest path to operationalizing this is to treat it like a governed production process with clear inputs, decision points, and outputs you can evidence during supervision. You are coordinating multiple teams: Security Operations (threat intel, detection, incident response), Vulnerability Management (scanning, patch governance), ICT Risk (risk acceptance and prioritization), IT Ops/Engineering (change execution), and Third-Party Risk (supplier advisories and exposure). Article 13 becomes the connective tissue and the proof layer. (Regulation (EU) 2022/2554, Article 13)

This page gives you requirement-level implementation guidance with concrete steps, artifacts to retain, common audit traps, and a practical execution plan you can run as a program. (Regulation (EU) 2022/2554, Article 13)

Regulatory text

Text (excerpt): “Financial entities shall have in place capabilities and staff to gather information on vulnerabilities and cyber threats, ICT-related incidents, in particular cyber-attacks, and analyse the impact they are likely to have on their digital operational resilience.” (Regulation (EU) 2022/2554, Article 13)

What the operator must do:
You must (1) maintain the people and tools needed to collect relevant information (threats, vulnerabilities, incidents), and (2) run an analysis process that evaluates likely impact to operational resilience, then (3) feed results into prioritization and corrective actions that improve resilience over time. Your evidence must show continuity (it happens as part of operations) and effectiveness (analysis changes what you do). (Regulation (EU) 2022/2554, Article 13)

Plain-English interpretation (what “learning and evolving” means in practice)

Article 13 expects an organizational “sensing and response” loop:

• Sensing: you intake signals from internal events (incidents, near misses, detections), external sources (threat intelligence, vulnerability disclosures), and third parties (supplier advisories and outages).
• Understanding: you translate signals into business and resilience impact for your environment, not a generic risk statement.
• Acting: you adjust controls, patch, tune detections, update procedures, and close gaps with tracked remediation.
• Proving: you retain records that show who analyzed what, what decisions were made, and what changes were implemented. (Regulation (EU) 2022/2554, Article 13)

Who it applies to (entity and operational context)

Entity scope: Financial entities in scope of DORA. (Regulation (EU) 2022/2554)

Operational scope (where auditors will look):

• Security operations and incident response: how you capture incident learnings, root cause, and follow-up actions. (Regulation (EU) 2022/2554, Article 13)
• Vulnerability management: how you identify vulnerabilities, assess exposure, prioritize fixes, and verify closure. (Regulation (EU) 2022/2554, Article 13)
• Threat intelligence and monitoring: how you gather threat information and translate it into changes in controls or response posture. (Regulation (EU) 2022/2554, Article 13)
• Third-party dependencies: how you incorporate supplier advisories, shared responsibility boundaries, and downstream exposure into analysis and remediation planning. (Regulation (EU) 2022/2554, Article 13)
• Governance: whether staffing, roles, and accountability are defined and sufficient for continuous operation. (Regulation (EU) 2022/2554, Article 13)

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

Use this as a minimum viable operating model. Adjust the tooling to your stack; keep the workflow.

1) Define ownership, staffing, and escalation

1. Name an accountable owner for Article 13 execution (often Head of Security Governance, CISO delegate, or ICT Risk). Document RACI across SOC, Vulnerability Management, IT Ops, ICT Risk, and Third-Party Risk. (Regulation (EU) 2022/2554, Article 13)
2. Document staffing coverage: roles required to run intake, analysis, and remediation tracking (not headcount numbers). Show backups and on-call alignment for incident-driven surges. (Regulation (EU) 2022/2554, Article 13)
3. Set escalation rules: what triggers a risk acceptance decision, crisis governance, or executive reporting. (Regulation (EU) 2022/2554, Article 13)

2) Build the “intake” layer (signals you gather)

1. Vulnerabilities: scanner findings, vendor disclosures, CERT-style advisories you subscribe to, internal pen test findings, and configuration drift reports. (Regulation (EU) 2022/2554, Article 13)
2. Threats: threat intel reports, ISAC/community alerts (if applicable), adversary TTP updates relevant to your tech stack, and targeted campaign notifications. (Regulation (EU) 2022/2554, Article 13)
3. Incidents: confirmed incidents and meaningful near misses, including cyber-attacks, plus operational issues that degrade resilience if they have an ICT dimension. (Regulation (EU) 2022/2554, Article 13)
4. Third parties: supplier security advisories, outage notifications, and contractual notification channels. Ensure each critical third party has a defined intake mailbox/ticket route. (Regulation (EU) 2022/2554, Article 13)

Operational tip: don’t let signals live in email. Route everything into a system of record (ticketing, GRC workflow, or case management) with timestamps, ownership, and status.

3) Standardize the “analysis” layer (impact to resilience)

Create a repeatable analysis template used across all signal types:

• Asset/context mapping: which business services, systems, data classes, and third parties are in scope for the issue.
• Likely impact: effect on availability, integrity, confidentiality, and recoverability; include operational dependencies (identity, network, cloud control plane).
• Exposure and feasibility: is it exploitable in your environment; are compensating controls in place.
• Decision outcome: remediate, mitigate, accept risk, or monitor; include decision authority. (Regulation (EU) 2022/2554, Article 13)

Keep the analysis lightweight enough that teams will actually use it, but structured enough to be auditable.

4) Turn analysis into action (remediation and improvement)

1. Create a remediation work item for each accepted action, with owner, due date, and verification method.
2. Track to closure: closure requires validation evidence (patch confirmation, config check, detection rule deployed, tabletop update performed).
3. Capture “lessons learned” for incidents: root cause, what failed, what detection missed, what playbook changes were made, and how you tested the change. (Regulation (EU) 2022/2554, Article 13)

5) Establish governance and metrics that withstand scrutiny (without inventing numbers)

1. Operational review cadence: run a recurring cross-functional review of open high-risk items, overdue remediation, and incident learnings.
2. Management reporting: produce a short dashboard that ties top issues to business services and confirms remediation progress.
3. Evidence readiness drills: periodically test whether you can produce end-to-end evidence for a sample vulnerability, a sample threat advisory, and a sample incident. (Regulation (EU) 2022/2554, Article 13)

Where Daydream fits naturally: Many teams struggle to keep obligation-to-evidence traceability clean across security tools, ticketing, and GRC. Daydream can act as the single register that maps Article 13 to accountable owners, operating controls, and the exact artifacts you will produce for supervisory review, then tracks corrective actions and validation evidence to closure.

Required evidence and artifacts to retain

Maintain a defensible evidence set that shows operation over time:

• Role and responsibility documentation: RACI, job role descriptions, on-call/escalation procedures. (Regulation (EU) 2022/2554, Article 13)
• Signal intake records: tickets/cases for vulnerability advisories, threat intel items, incident records, and third-party notifications with timestamps and triage outcomes. (Regulation (EU) 2022/2554, Article 13)
• Impact analysis worksheets: completed templates tied to each material signal, showing rationale and decision authority. (Regulation (EU) 2022/2554, Article 13)
• Remediation tracking: corrective action plan register, linked work items, change records, and closure validation (screenshots, reports, config states). (Regulation (EU) 2022/2554, Article 13)
• Lessons learned outputs: post-incident review reports and evidence of implemented improvements. (Regulation (EU) 2022/2554, Article 13)
• Management oversight: minutes from governance meetings, risk acceptance approvals, and escalations. (Regulation (EU) 2022/2554, Article 13)

Common exam/audit questions and hangups

Expect these lines of questioning:

• “Show me the capability and staff.” Who does intake, who analyzes, who approves risk acceptance, and who verifies closure? (Regulation (EU) 2022/2554, Article 13)
• “Prove you analyze impact, not just severity.” A CVSS score is not impact to resilience; auditors will ask how it affects business services and recovery. (Regulation (EU) 2022/2554, Article 13)
• “Demonstrate end-to-end traceability.” Pick one incident and show: detection → response → lessons learned → control change → validation. (Regulation (EU) 2022/2554, Article 13)
• “How do third parties feed your learning loop?” Show supplier advisories intake, analysis, and your response actions. (Regulation (EU) 2022/2554, Article 13)

Frequent implementation mistakes (and how to avoid them)

Mistake	Why it fails	Fix
Threat intel subscription with no action path	You gather information but don’t show impact analysis or operational change	Require each relevant intel item to produce an assessment record and a decision (remediate/monitor/etc.) (Regulation (EU) 2022/2554, Article 13)
Vulnerability management treated as “scan and patch”	Resilience impact and governance decisions are missing	Add business service mapping and formal risk acceptance workflow for deferrals (Regulation (EU) 2022/2554, Article 13)
Incident reviews are ad hoc	You cannot show systematic learning	Standardize PIR templates and require tickets for every improvement item to closure (Regulation (EU) 2022/2554, Article 13)
Evidence scattered across tools	Supervisory response becomes slow and inconsistent	Maintain a single evidence index/register that points to source-of-truth records and owners (Regulation (EU) 2022/2554, Article 13)
Third-party signals ignored	Material exposures can sit outside your SOC visibility	Set intake routes, SLAs in contracts where feasible, and joint remediation tracking for critical providers (Regulation (EU) 2022/2554, Article 13)

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so you should plan based on supervisory expectations embedded in the text: competent authorities can test whether you have staffing and operational capability, and they can ask for demonstrable evidence that you learned from vulnerabilities, threats, and incidents and improved resilience accordingly. (Regulation (EU) 2022/2554, Article 13)

From a risk standpoint, Article 13 gaps usually surface as:

• repeated incidents with similar root causes,
• large backlogs of unremediated vulnerabilities without documented rationale,
• slow or inconsistent response to supplier advisories,
• inability to assemble evidence quickly under supervisory request. (Regulation (EU) 2022/2554, Article 13)

Practical 30/60/90-day execution plan

First 30 days (stabilize and make it auditable)

• Appoint the accountable owner and publish RACI across security, IT, ICT risk, and third-party risk. (Regulation (EU) 2022/2554, Article 13)
• Create a single “Article 13 register” mapping: signal sources → analysis template → remediation tracking → evidence locations.
• Standardize the impact analysis template and require its use for new high-priority vulnerabilities, significant threat advisories, and incidents. (Regulation (EU) 2022/2554, Article 13)

By 60 days (operate the loop across all signal types)

• Route vulnerability, threat, incident, and third-party advisories into a consistent system of record with clear triage states. (Regulation (EU) 2022/2554, Article 13)
• Stand up recurring cross-functional review with minutes and action tracking.
• Implement risk acceptance governance for remediation deferrals, including defined approvers and expiry/review triggers. (Regulation (EU) 2022/2554, Article 13)

By 90 days (prove outcomes and close gaps)

• Run an evidence-readiness drill: produce end-to-end evidence for one incident, one vulnerability disclosure, and one third-party advisory, including closure proof. (Regulation (EU) 2022/2554, Article 13)
• Trend recurring root causes and show at least one control/process improvement implemented and validated. (Regulation (EU) 2022/2554, Article 13)
• Formalize continuous improvement backlog ownership (who prioritizes, who funds, who validates) and integrate it with your change management process. (Regulation (EU) 2022/2554, Article 13)

Frequently Asked Questions

What counts as “capabilities and staff” under the Article 13: learning and evolving requirement?

It means you have defined roles and operating processes to gather signals and analyze their impact, not just a tool purchase. You should be able to name accountable owners, show procedures, and demonstrate sustained execution with evidence. (Regulation (EU) 2022/2554, Article 13)

Does a vulnerability scanner alone satisfy Article 13?

No. Scanning helps you gather information, but Article 13 also requires impact analysis and a process to translate findings into resilience improvements with tracked remediation and validation. (Regulation (EU) 2022/2554, Article 13)

How do we show “impact on digital operational resilience” in a way auditors accept?

Tie each material issue to business services and operational dependencies, then document likely effects on availability, integrity, confidentiality, and recoverability. Keep the analysis record linked to the remediation decision and closure evidence. (Regulation (EU) 2022/2554, Article 13)

How should third-party advisories be handled for Article 13?

Treat them as first-class intake items with triage, impact analysis for your specific deployments, and tracked actions (mitigation, configuration change, monitoring, or risk acceptance). Keep the advisory, your analysis, and your closure proof together. (Regulation (EU) 2022/2554, Article 13)

What evidence is most commonly missing during supervisory review?

Teams often have raw data (scan results, alerts) but lack the decision trail: who assessed impact, what was decided, and proof the fix was implemented and validated. Build an evidence index/register so you can produce end-to-end records quickly. (Regulation (EU) 2022/2554, Article 13)

Can we centralize Article 13 evidence in GRC even if execution happens in security tools?

Yes, and it is often the cleanest approach. Keep execution in source systems, but maintain a governed register that points to source-of-truth records and links analysis to remediation and validation artifacts. (Regulation (EU) 2022/2554, Article 13)