Article 47: Cooperation with structures and authorities established by Directive (EU) 2022/2555

Article 47 requires you to be ready to cooperate with, and respond consistently to, supervisory coordination between your DORA competent authority and the NIS2 Cooperation Group structures, so supervisory exchanges don’t stall because your internal owners, evidence, or regulatory-response workflow are unclear. Operationalize it by assigning accountable points of contact, standardizing regulator request handling, and maintaining a durable evidence pack tied to ICT risk controls. (Regulation (EU) 2022/2554, Article 47)

Key takeaways:

• Treat Article 47 as an operational readiness requirement: clear owners, clear workflow, fast evidence retrieval. (Regulation (EU) 2022/2554, Article 47)
• Build a “supervisory cooperation pack” that maps DORA obligations to controls, owners, and artifacts your competent authority may request. (Regulation (EU) 2022/2554, Article 47)
• Run repeatable response drills and track corrective actions to prove you can support supervisory exchanges without chaos. (Regulation (EU) 2022/2554, Article 47)

The target keyword, article 47: cooperation with structures and authorities established by directive (eu) 2022/2555 requirement, reads like a regulator-to-regulator coordination clause, and it is. For operators, the practical impact is simple: your competent authority may need information quickly to support supervisory exchanges that touch digital operational resilience, cyber risk, and incidents across financial entities. Article 47 creates the expectation that supervisory cooperation mechanisms function in practice, not only on paper. (Regulation (EU) 2022/2554, Article 47)

You do not “comply” with Article 47 by writing a standalone policy. You comply by ensuring your organization can (a) identify the right internal owners, (b) assemble correct and consistent information, and (c) deliver it through an approved workflow under regulatory time pressure. That means joining up Compliance, ICT risk management, security operations, resilience/BCM, and third-party risk management so they can answer the same question the same way. (Regulation (EU) 2022/2554, Article 47)

This page gives requirement-level implementation guidance you can put into your governance system immediately: roles, procedures, artifacts, and exam-ready questions to pressure-test your readiness.

Regulatory text

Excerpt (operator-relevant): Article 47 provides that, to foster cooperation and supervisory exchanges between competent authorities designated under DORA and the Cooperation Group established by Article 14 of Directive (EU) 2022/2555, the ESAs and competent authorities may participate in the Cooperation Group’s activities for matters related to their supervisory activities concerning financial entities, and may request to be invited to participate. (Regulation (EU) 2022/2554, Article 47)

What the operator must do with this text:
Even though the clause describes inter-authority cooperation, your obligation is indirect but real: you must be able to support your competent authority’s supervisory work without delays caused by unclear accountability, inconsistent data, or missing evidence. In practice, that means you need a regulator-ready process for assembling and validating ICT risk and resilience information that could be exchanged across supervisory structures. (Regulation (EU) 2022/2554, Article 47)

Plain-English interpretation

Article 47 expects supervisory cooperation to work smoothly. Your organization should expect information requests that involve ICT risk, resilience controls, incident handling, and third-party dependencies, and be able to respond with validated, consistent materials. If your internal teams give different answers, cannot find test results, or cannot show remediation closure, you create supervisory friction and increase scrutiny. (Regulation (EU) 2022/2554, Article 47)

Think of it as “cross-authority exam readiness”: you are preparing for coordinated oversight where questions and follow-ups may move between bodies. Your job is to make your side of the exchange reliable.

Who it applies to (entity and operational context)

Applies to: financial entities in scope of DORA that are supervised by a DORA competent authority and may be subject to supervisory information-gathering related to ICT risk and digital operational resilience. (Regulation (EU) 2022/2554)

Operational contexts where it bites most:

• Incident reporting and crisis communications: regulators may seek consistent timelines, impact statements, and control narratives aligned across functions. (Regulation (EU) 2022/2554, Article 47)
• Third-party dependency and concentration risk: requests often require pulling contracts, service maps, and assurance evidence rapidly. (Regulation (EU) 2022/2554)
• Testing and remediation governance: you may need to show that findings are owned, tracked, and closed with proof. (Regulation (EU) 2022/2554, Article 47)
• Multi-country operations: different supervisory audiences, same underlying facts. Consistency becomes a control.

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

1) Assign accountable owners and an escalation path

Create a small, named “supervisory cooperation” RACI that covers:

• Regulatory response owner: accountable for end-to-end regulator intake, coordination, and submission.
• ICT risk owner: accountable for risk positions, control descriptions, KRIs, and exceptions.
• Security operations owner: accountable for incident facts, investigation artifacts, and containment/eradication evidence.
• Third-party risk owner: accountable for third-party inventories, criticality, assurance, and contract clauses.
• Legal reviewer: accountable for privilege, confidentiality, and disclosure posture.

Deliverable: a one-page accountability sheet that is exam-ready and kept current. (Regulation (EU) 2022/2554, Article 47)

2) Build a single register that maps Article 47 to controls and evidence

You need traceability from “requirement” to “how we operate” to “what we can show.” Minimum fields to include:

• Requirement statement (Article 47)
• Control objective (supervisory cooperation readiness)
• Control owners (primary + backups)
• Evidence artifacts (exact filenames or system-of-record locations)
• Last validation date and open gaps

This is where tools like Daydream fit naturally: you can maintain a control-to-evidence register that stays current and makes regulator responses repeatable instead of artisanal.

3) Implement a regulator request intake-and-response workflow

Document a workflow that answers these operational questions:

• How do requests enter (email, portal, onsite)?
• Who triages scope and due date?
• Who validates data accuracy across functions?
• Who approves the final response (Compliance/Legal sign-off)?
• How do you track commitments and follow-ups?

Practical control: require each submission to have (a) a clear owner, (b) a version-controlled response pack, and (c) recorded approvals. (Regulation (EU) 2022/2554, Article 47)

4) Standardize the “supervisory cooperation pack”

Maintain a ready-to-send set of materials that commonly supports supervisory exchanges. Tailor it to your business, but most teams include:

• ICT risk management framework overview and governance minutes extracts
• Incident management policy and recent tabletop/exercise summary
• Key resilience testing plan and latest results summary
• Third-party inventory focused on critical ICT service providers, with assurance evidence pointers
• Corrective action log with validation evidence for closures

Keep it short and indexed. Regulators reward clarity.

5) Run readiness drills and close gaps with tracked corrective actions

Operate this as a control, not a one-time project:

• Simulate a request (“Provide evidence of X”)
• Time-box internal collection
• Validate consistency between ICT risk, security, and third-party teams
• Record defects (missing evidence, conflicting metrics, outdated ownership)
• Create corrective actions with owners and closure evidence

The point is to prove your organization can execute under pressure and improve the process over time. (Regulation (EU) 2022/2554, Article 47)

Required evidence and artifacts to retain

Keep artifacts that prove the process exists and operates:

• RACI / points-of-contact list (named roles, backups, escalation steps)
• Regulatory response procedure (intake, triage, approvals, submission, retention)
• Request log (requests received, owners, due dates, status, submission package reference)
• Approval records (Compliance and Legal sign-offs; version history)
• Control-to-evidence register mapping Article 47 readiness to the exact evidence locations
• Drill outputs (scenario, participants, gaps found, corrective actions)
• Corrective action tracking (owner, target, closure evidence, validation step)

If you cannot produce these quickly, supervision becomes a scavenger hunt.

Common exam/audit questions and hangups

Auditors and supervisors tend to probe execution, not intent:

• Who is accountable for coordinating responses to your competent authority on ICT resilience topics? (Regulation (EU) 2022/2554, Article 47)
• Show the last regulator request you handled and the evidence that Legal/Compliance approved the response.
• How do you prevent inconsistent answers from Security vs ICT Risk vs Third-Party Risk?
• Where is your system of record for remediation items arising from resilience testing or incidents?
• How do you ensure third-party evidence (SOC reports, certifications, SLAs, incident notifications) can be produced on demand?

Hangup to expect: teams confuse “we have the policy” with “we can prove operation.” Your file set and logs matter.

Frequent implementation mistakes and how to avoid them

1. No single throat to choke for regulator responses
   Fix: name an accountable owner with authority to task other functions, plus a backup.

2. Evidence scattered across inboxes and chat threads
   Fix: define a system of record and require that final submission packs are stored with version control and approvals.

3. Conflicting metrics and definitions (incident severity, downtime, “critical” third party)
   Fix: maintain a controlled glossary and align reporting templates across functions.

4. Over-collection and under-indexing
   Fix: keep an indexed pack with short narratives and pointers to deeper artifacts. Make it navigable.

5. No remediation discipline
   Fix: corrective actions need owners, closure criteria, and validation evidence. Otherwise every request reopens old wounds.

Enforcement context and risk implications

No public enforcement cases were provided in the supplied sources for Article 47, so this page does not list specific actions. (Regulation (EU) 2022/2554, Article 47)

Operationally, the risk is supervisory: poor cooperation readiness increases the likelihood of extended information requests, more intrusive examinations, and forced remediation timelines. Article 47 also amplifies reputational and governance risk because cross-authority exchanges can surface inconsistencies faster.

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

You asked for speed; here is a plan you can run without pretending that every organization moves at the same pace.

First 30 days (Immediate setup)

• Appoint the regulatory response owner, backups, and cross-functional contacts. (Regulation (EU) 2022/2554, Article 47)
• Publish a regulator request workflow with intake channels, triage, approvals, and retention rules.
• Create the control-to-evidence register entry for Article 47 and link it to real artifacts (not placeholders).
• Stand up a request log (even if it starts as a simple tracker).

By 60 days (Make it repeatable)

• Build the first version of the supervisory cooperation pack with an index and owners for each section.
• Align definitions across ICT risk, Security, BCM, and Third-Party Risk for terms that appear in regulatory exchanges.
• Run a readiness drill; capture gaps and open corrective actions. (Regulation (EU) 2022/2554, Article 47)

By 90 days (Prove operation)

• Close the highest-risk corrective actions (missing evidence, unclear ownership, inconsistent reporting).
• Re-run the drill using a different scenario (incident-driven or third-party-driven) and show improved outputs.
• Review board/management reporting so the same facts and metrics flow through governance and supervisory responses.

If you already run a GRC platform, integrate the register, workflow, and evidence pointers there. If you don’t, Daydream can act as the operational layer that keeps the mapping and artifacts current and searchable across teams.

Frequently Asked Questions

Does Article 47 require my organization to participate directly in the NIS2 Cooperation Group?

Article 47 describes participation and cooperation between ESAs/competent authorities and the NIS2 Cooperation Group structures. Your practical obligation is to support your competent authority with accurate, consistent information tied to ICT risk and resilience. (Regulation (EU) 2022/2554, Article 47)

What is the minimum “evidence pack” I should have ready?

Keep a regulator request workflow, a request log, a named RACI, and an indexed set of core ICT risk/resilience artifacts with clear owners and storage locations. Add drill outputs and corrective action closure evidence to show the process operates. (Regulation (EU) 2022/2554, Article 47)

How do I prevent inconsistent answers across Security, ICT Risk, and Third-Party Risk?

Standardize definitions and templates, then require a single coordination owner and a documented review step before submission. Store the final approved narrative as the system-of-record response so future answers stay consistent. (Regulation (EU) 2022/2554, Article 47)

Where does third-party risk management fit into Article 47 cooperation readiness?

Supervisory exchanges often involve critical service dependencies, outsourced ICT services, and assurance evidence. Your third-party inventory and assurance artifacts should be indexed and retrievable through the same regulatory response workflow. (Regulation (EU) 2022/2554)

If I have never received a regulator request, how do I show compliance?

Prove readiness through governance artifacts: assigned owners, documented workflows, an evidence register, and completed drills with tracked remediation. Supervisors generally accept operational proof over “we’ve never been asked.” (Regulation (EU) 2022/2554, Article 47)

What should Legal review in a regulatory response under this requirement?

Legal should review confidentiality, contractual restrictions (including third-party information sharing), privilege considerations, and consistency with prior submissions. Keep approval records tied to the final submission pack. (Regulation (EU) 2022/2554, Article 47)