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Biases in Threat-Led Penetration Testing – maintaining the TIBER spirit under DORA

Author

Listed:
  • Konrad Richter
  • Romana Wellischowitsch

    (Oesterreichische Nationalbank)

Abstract

The EU’s Digital Operational Resilience Act (DORA) came into force in January 2025. It requires financial entities to perform Threat-Led Penetration Testing (TLPT) to find weaknesses in their cybersecurity. TLPT was previously optional, but now that it is mandatory, there is a risk that it could become a formality that does not provide any real benefits. This article looks at key biases that could make TLPT less effective and outlines strategies to address them.

Suggested Citation

  • Konrad Richter & Romana Wellischowitsch, 2025. "Biases in Threat-Led Penetration Testing – maintaining the TIBER spirit under DORA," Financial Stability Report, Oesterreichische Nationalbank (Austrian Central Bank), issue 50, pages 1-6.
    • Handle: RePEc:onb:oenbfs:y:2025:i:50:b:2
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    File URL: https://www.oenb.at/dam/jcr:cb3c2fce-8884-4a6b-8b71-4ab921f0ac47/FSR-50_Biases-in-Threat-Led-Penetration-Testing.pdf
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    JEL classification:

    • G28 - Financial Economics - - Financial Institutions and Services - - - Government Policy and Regulation
    • K23 - Law and Economics - - Regulation and Business Law - - - Regulated Industries and Administrative Law
    • L86 - Industrial Organization - - Industry Studies: Services - - - Information and Internet Services; Computer Software
    • O33 - Economic Development, Innovation, Technological Change, and Growth - - Innovation; Research and Development; Technological Change; Intellectual Property Rights - - - Technological Change: Choices and Consequences; Diffusion Processes

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