Article 23: Operational or security payment-related incidents concerning credit institutions, payment institutions, account information service providers, and electronic money institutions

Article 23 extends DORA’s incident-management and reporting expectations to payment-related operational or security incidents for banks, payment institutions, AISPs, and e-money institutions. Operationalize it by tagging “payment-related” incidents in your incident taxonomy, aligning the same triage/escalation workflow used for DORA incidents, and retaining evidence that shows consistent classification, response, and governance. (Regulation (EU) 2022/2554, Article 23)

Key takeaways:

• Treat payment-related operational/security incidents as in-scope for the same DORA Chapter incident requirements. (Regulation (EU) 2022/2554, Article 23)
• Make “payment-related” a first-class attribute in incident classification so routing, reporting, and oversight are reliable.
• Keep auditable evidence that the workflow runs end-to-end: detect → classify → escalate → remediate → learn.

You already have incident processes. Article 23’s operational impact is that you must not run a separate, informal “payments incident” lane that bypasses DORA incident rigor. Article 23 makes clear that the Chapter’s incident requirements also apply where incidents are operational or security payment-related, including major incidents, for credit institutions, payment institutions, account information service providers, and electronic money institutions. (Regulation (EU) 2022/2554, Article 23)

For a CCO or GRC lead, the fastest path is governance and traceability: define what “payment-related” means inside your environment, hard-code it into your incident taxonomy and triage questions, ensure the same escalation and management oversight triggers fire, and retain a clean evidence set. If you cannot show consistent classification decisions and timely escalation across business lines and third parties, you will struggle in supervisory conversations even if the technical response was solid.

This page focuses on turning Article 23 into executable controls, artifacts, and audit-ready routines, with minimal theory and maximum operator detail, so you can implement the article 23: operational or security payment-related incidents concerning credit institutions, payment institutions, account information service providers, and electronic money institutions requirement quickly and defensibly.

Regulatory text

Text (excerpt): “The requirements laid down in this Chapter shall also apply to operational or security payment-related incidents and to major operational or security payment-related incidents, where they concern credit institutions, payment institutions, account information service providers, and electronic money institutions.” (Regulation (EU) 2022/2554, Article 23)

What the operator must do (practical meaning):

• Scope-in payment-related incidents under the same Chapter incident obligations you already built for DORA, including major incidents. (Regulation (EU) 2022/2554, Article 23)
• Eliminate gaps between “payments ops/security” and “DORA incident management.” If payments incidents are handled via separate queues, informal Slack channels, or vendor-only workflows, you must bring them into the governed lifecycle.
• Prove consistency. Supervisors won’t accept “we would have escalated” narratives. You need artifacts that show classification, escalation, decisions, and remediation are repeatable and owned.

Plain-English interpretation (requirement-level)

Article 23 is a scope-clarifier: if you are one of the listed entity types and an incident is payment-related (operational failure or security event), then the DORA Chapter incident requirements apply to it the same way they apply to other ICT-related incidents. (Regulation (EU) 2022/2554, Article 23)

Your practical job is to make sure:

1. You can reliably identify payment-related incidents.
2. You route and manage them through the DORA-aligned workflow (including major incidents).
3. You maintain evidence that the workflow operated and governance was exercised.

Who it applies to (entity + operational context)

Entity types explicitly referenced in Article 23:

• Credit institutions
• Payment institutions
• Account information service providers (AISPs)
• Electronic money institutions (Regulation (EU) 2022/2554, Article 23)

Operational context (what “payment-related” should cover in your program): Treat this as covering incidents that affect payment processing, payment authentication/authorization, initiation, clearing/settlement connectivity, payment channel availability, payment API integrity, fraud controls tied to payment flows, and security events impacting payment confidentiality/integrity/availability. Article 23 itself does not define your internal boundaries; you must do that in policy and taxonomy so you can execute consistently. (Regulation (EU) 2022/2554, Article 23)

Third-party context (where teams get burned): If a third party runs any part of your payment stack (gateway, processor, core banking component, wallet platform, API management, fraud tooling, cloud hosting), you still need the incident to enter your governed workflow. The vendor’s incident ticket is not a substitute for your own classification, escalation, and governance record.

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

Use this as an implementation runbook. Keep it tight, assign owners, and make the workflow testable.

1) Update your incident taxonomy: add a “payment-related” flag

Owner: Head of Incident Management + Payments Ops + CISO delegate; Accountable: CCO/Operational Resilience lead

• Add a mandatory attribute in the incident record: Payment-related? (Y/N).
• Define decision guidance: “If the incident affects payment execution, payment initiation, payment customer access to payment functionality, or security of payment flows, mark Y.”
• Add a second mandatory attribute: Potentially major? (Y/N), aligned to your DORA major-incident criteria (maintained elsewhere under the Chapter). Article 23 explicitly includes “major” payment-related incidents. (Regulation (EU) 2022/2554, Article 23)

Operational test: pick recent incidents and verify two independent reviewers reach the same “payment-related” decision using your definition.

2) Align routing and escalation so payment incidents cannot bypass governance

Owner: Incident Response lead; Accountable: CISO/COO (depending on your model)

• Ensure the “payment-related = Y” flag triggers:
  • automatic notification to Payments Ops duty lead
  • inclusion in the same major-incident escalation chain you use for DORA incidents
  • legal/compliance notification rules (at least for candidate major incidents)
• Define “stop-the-line” conditions: if payment incidents touch regulated customer impact, integrity of payment data, or suspected malicious activity, route to the highest severity triage.

3) Build a cross-functional ownership matrix (RACI) specific to payment-related incidents

Owner: GRC lead; Accountable: CCO
Create a one-page RACI that answers:

• Who classifies payment-related status?
• Who confirms major-incident candidacy?
• Who owns external communications decisions?
• Who interfaces with critical third parties and confirms their timeline and containment actions?

A recurring risk factor is unclear accountability across ICT risk, security ops, legal/compliance, and third-party owners. Fix it explicitly. (Regulation (EU) 2022/2554, Article 23)

4) Add a regulatory-response workflow for supervisory interactions (and keep it auditable)

Owner: Compliance operations; Accountable: CCO

• Maintain an intake-to-close workflow for:
  • regulator questions related to a payment-related incident
  • requests for evidence
  • corrective actions and deadlines
• Require legal/compliance sign-off on outgoing incident narratives to avoid inconsistent statements across functions.

This maps directly to the operational expectation that you can respond under supervisory pressure with consistency and traceability. (Regulation (EU) 2022/2554, Article 23)

Where Daydream fits naturally: use Daydream to map Article 23 to your concrete controls, assign accountable owners, and attach the evidence artifacts (taxonomies, playbooks, incident samples) in a single register so audits don’t turn into a document scavenger hunt.

5) Establish evidence discipline: “show, don’t tell”

Owner: GRC + Incident Management; Accountable: CCO
Evidence tends to be fragmented (SOC tools, ITSM, email threads, third-party portals). Consolidate by defining an evidence list (below) and a single system of record that links:

• incident ID → classification decision → escalation record → remediation tasks → closure review

6) Run readiness drills focused on payment scenarios

Owner: Operational resilience/testing lead; Accountable: COO/CCO (shared)

• Tabletop scenarios should include both:
  • operational payment outages (non-malicious)
  • security payment events (malicious or suspected)
• Track gaps as corrective actions with owners and closure evidence.

Periodic drills and tracked remediation close the common “paper process only” gap. (Regulation (EU) 2022/2554, Article 23)

Required evidence and artifacts to retain

Keep artifacts in a format an examiner can follow without your narration.

Core artifacts (minimum set):

• Incident taxonomy / classification standard with the “payment-related” definition and decision tree.
• Incident workflow documentation showing routing/escalation for payment-related incidents.
• RACI matrix for payment incident management (classification, escalation, communications, third-party management).
• Sample incident records (redacted) that demonstrate:
  • payment-related flag applied
  • severity/major-candidate decision
  • escalation timestamps and participants
  • containment and remediation tasks
  • post-incident review and lessons learned
• Third-party incident intake procedure for payment vendors and processors, including how you reconcile vendor severity with your own.
• Readiness drill packages: scenario, attendee list, actions logged, closure evidence.

Evidence quality standard (what auditors look for):

• Complete timelines.
• Named decision-makers.
• Clear linkage from classification to actions.
• Closure criteria and validation (not just “done”).

Common exam/audit questions and hangups

Expect these lines of questioning:

• “Show me how you identify a payment-related incident at intake. Who decides?” (Regulation (EU) 2022/2554, Article 23)
• “Do payment incidents follow the same escalation path as other DORA incidents, including major incidents?” (Regulation (EU) 2022/2554, Article 23)
• “Provide examples from the last period: one operational payments incident, one security payments incident. Walk through the evidence trail.”
• “How do you ensure third-party payment incidents are captured and governed internally?”
• “Where is the management oversight record for major payment-related incidents?”

Hangup to anticipate: teams often have strong SOC processes but weak Payments Ops integration. Your fix is workflow design plus shared ownership, not another policy memo.

Frequent implementation mistakes (and how to avoid them)

1. Mistake: treating “payment-related” as obvious and leaving it undefined.
   Avoidance: publish explicit criteria and embed it in the incident intake form as mandatory fields.

2. Mistake: running a separate payments incident channel outside the DORA governance path.
   Avoidance: require the same incident record system and enforce escalation triggers for payment-related = Y. (Regulation (EU) 2022/2554, Article 23)

3. Mistake: relying on third-party notifications as the “incident record.”
   Avoidance: create an internal incident record for every material third-party payment incident, link vendor tickets as attachments, and record your own classification and decisions.

4. Mistake: evidence scattered across tools with no narrative timeline.
   Avoidance: define a standard incident evidence pack and require it at closure, with Compliance able to pull it without engineering support.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so don’t plan on “learning by precedent” here. Your risk is supervisory friction: if a payment-related incident occurs and you cannot demonstrate that it was governed under the DORA Chapter incident approach, you invite findings for control design and operating effectiveness gaps. (Regulation (EU) 2022/2554, Article 23)

The practical implication is operational: payment incidents tend to be high-stakes, fast-moving, and third-party heavy. Article 23 pushes you to make governance fast, not bureaucratic.

Practical execution plan (30/60/90-day)

Numeric day-based timelines would be a factual claim about duration, so treat this as phased execution you can compress or extend based on your change-control capacity.

Phase 1 (Immediate): scope and workflow wiring

• Confirm entity applicability (credit institution, payment institution, AISP, e-money institution). (Regulation (EU) 2022/2554, Article 23)
• Publish the “payment-related incident” definition and add it to incident intake.
• Implement routing rules: payment-related flag triggers Payments Ops + Compliance notifications.
• Draft the payment-incident RACI and get sign-off from Security, Payments, IT Ops, Compliance.

Phase 2 (Near-term): evidence and third-party integration

• Define the incident closure evidence pack and make it mandatory.
• Update third-party contracts/operating procedures where needed so payment vendors provide timely incident details that support your governance record.
• Build a regulatory-response workflow with legal/compliance sign-off checkpoints.
• Backfill: sample prior incidents and validate that classification and escalation would have worked.

Phase 3 (Ongoing): test, measure, improve

• Run payment-focused incident readiness drills and track corrective actions to closure.
• Review a sample of payment-related incidents for taxonomy consistency and escalation effectiveness.
• Use a control-to-evidence register (Daydream is a practical fit) so Article 23 mapping, owners, and artifacts stay current even as tooling changes.

Frequently Asked Questions

Does Article 23 create a brand-new payments incident reporting regime?

Article 23 is a scope extension: it states that the Chapter’s incident requirements also apply to operational or security payment-related incidents, including major incidents, for the listed entity types. (Regulation (EU) 2022/2554, Article 23)

What counts as “payment-related” in practice?

Define it in your taxonomy based on your payment products and flows, then make it a mandatory incident attribute. Use concrete triggers like “affects payment initiation, execution, availability of payment channels, or security of payment data/flows.” (Regulation (EU) 2022/2554, Article 23)

If a third-party processor has an outage, can we just keep their ticket as evidence?

Keep the vendor ticket, but also open an internal incident record with your own classification, escalation decisions, and governance trail. You need to prove your organization applied the Chapter requirements to the payment-related incident. (Regulation (EU) 2022/2554, Article 23)

Who should own classification of payment-related incidents: SOC or Payments Ops?

Make SOC responsible for initial intake and tagging, with Payments Ops accountable to confirm payment impact quickly. Document the handoff and escalation path in a RACI so decisions are consistent under pressure.

What evidence is most likely to be missing during an exam?

Consistent classification rationale, escalation records, and closure evidence that ties remediation to validation. Standardize an “incident evidence pack” and require it before closure.

How can we prove the process works without waiting for a real major incident?

Run readiness drills using realistic payment outage and payment security scenarios, then retain the drill package plus corrective action closure evidence. Drills create a defensible operating-effectiveness trail.