Field note

Field note #149 — F-WF-DORA-TPR trilogy ships: DORA Art.28/30 ICT third-party risk management playbook complete

  • field-note
  • g-01
  • g-02
  • g-03
  • dora
  • third-party-risk
  • ict-tpr
  • art-28
  • art-30
  • chapter-v
  • cacao
  • playbook
  • n8n
  • temporal
  • langgraph
  • digital-commons
  • field-note-149

Field note one hundred and forty-nine. The F-WF-DORA-TPR trilogy lands. DORA Chapter V — ICT third-party risk management under Articles 28 and 30 — now has a shipped lifecycle spine on the framework: pre-contractual assessment, clause verification, register-of-information entry, periodic re-scoring, and exit-strategy attestation, described once as a portable CACAO v2 playbook and compiled into the three reference targets an operator already runs.

Alongside F-WF-DORA-SELFASSESS (Chapter II ICT risk management roll-up) and F-WF-DORA-TLPT (Chapter IV threat-led penetration testing programme), the DORA surface on the commons now carries three complete lifecycle spines. Chapter V was the last gap.

What shipped

Three framework PRs, all merged to main today:

  • #721 — F-WF-DORA-TPR SKELETON. The CACAO v2 playbook. content/playbooks/dora_tpr_management.yaml pins the five-step lifecycle (onboarding, clause-check, register-entry, periodic-review, exit-assessment) as an auditable, replayable, restart-safe workflow shape. Adapter surfaces are declared — critical-or-important-function register, pre-contractual risk-assessment rubric, contract repository, Article 30 clause-shape rubric, register sink, runtime supply-chain-evidence source, exit-strategy discipline — and left for the operator to wire. The playbook does not embed the rubric, does not choose the register store, does not schedule the periodic-review cadence. It ships the shape.
  • #722 — F-WF-DORA-TPR CORE. The three-target compile examples land under examples/{n8n,temporal,langgraph}/dora_tpr_management/ with the byte-parity golden tests wired into CI. Same CACAO source, three compiled artifacts, cross-target parity enforced.
  • #723 — F-WF-DORA-TPR EXTEND. The practitioner cookbook at docs/cookbook/dora_tpr_management.md walks the five lifecycle atoms end to end, wires the playbook through all three compile targets, states the boundary against neighbouring playbooks (supply_chain_security, contractual_obligations_tracker, dora_ict_risk_selfassess), and flips the ROADMAP entry to Shipped.

Why an EU financial entity reads this

DORA is directly applicable across the EU financial sector — credit institutions, payment institutions, investment firms, insurance and reinsurance undertakings, crypto-asset service providers under MiCA, and the long list at Article 2. Chapter V places ICT third-party risk management inside the same accountability envelope as Chapter II. The management body remains ultimately responsible for the risks the entity carries through its ICT third-party service providers; the supervisor reads the register-of- information as the evidence of that discharge.

The five obligation atoms this playbook operates against:

  • Art. 28(4) — pre-contractual risk assessment. Before entering a contractual arrangement with an ICT third-party service provider, the entity assesses criticality, sub-outsourcing chain, data-location, and concentration exposure. The playbook keys on the operator’s documented rubric; the shape is portable.
  • Art. 30(2)/(3) — key contractual provisions. Every ICT third-party contract carries a closed clause set (service description, data-location, sub- outsourcing, service levels, audit rights, exit provisions, and the rest). The playbook step verifies the negotiated contract against the operator’s Article 30 clause-shape rubric before it moves.
  • Art. 28 — register of information. The register row composes and publishes to the operator’s register sink. What the supervisor reads.
  • Art. 28(8) — periodic re-scoring. On the operator’s documented cadence, criticality is re- scored with the runtime supply-chain-evidence stream folded in. Changes propagate to the register.
  • Art. 28(8) — exit-strategy attestation. A dated attestation on a documented trigger. The exit is a first-class lifecycle atom, not an afterthought.

An operator running Chapter II against the dora_ict_risk_selfassess playbook, Chapter IV against dora_tlpt_programme, and Chapter V against this one now has the DORA operational-resilience spine described once and compiled into whatever target the stack already runs.

The three DORA spines on the framework

  • playbook.dora_ict_risk_selfassess@v1 — the Chapter II ICT risk management framework self- assessment roll-up on Articles 6 / 7 / 8 / 10 / 11. Whole-framework posture.
  • playbook.dora_tlpt_programme@v1 — the Chapter IV Articles 24 / 26 threat-led penetration testing programme lifecycle.
  • playbook.dora_tpr_management@v1 — the Chapter V Articles 28 / 30 ICT third-party risk management lifecycle. Ships today.

Three chapters, three portable workflows, three byte-parity golden test suites. Same commons voice across all three.

The G-01 / G-02 / G-03 signal

  • G-01 — regime coverage. DORA Chapters II, IV, and V each carry a shipped operational spine now. The operational-resilience surface reads as a coherent set rather than three separate landings.
  • G-02 — CACAO v2 as the portable substrate. All three DORA playbooks are CACAO v2 source. The clause-check step, the register-entry step, and the exit-strategy attestation step are all playbook atoms the operator’s evidence chain can point at.
  • G-03 — three-target parity. The CORE tier lands n8n, Temporal, and LangGraph examples with byte- parity golden tests. Operators pick the target that matches their stack.

Where to look

  • Framework repo:
    • content/playbooks/dora_tpr_management.yaml — the CACAO v2 source.
    • examples/n8n/dora_tpr_management/, examples/temporal/dora_tpr_management/, examples/langgraph/dora_tpr_management/ — the three compile-target examples.
    • docs/cookbook/dora_tpr_management.md — the practitioner walkthrough.
    • ROADMAP.md — the F-WF-DORA-TPR entry now reads Shipped.

If you run an EU financial entity under DORA scope and your Article 28 register-of-information is a spreadsheet held together by will, the walkthrough is the shortest path to a portable, auditable spine that compiles into whichever orchestrator you already run.

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