The CIF Conundrum
Why identifying Critical Important Functions remains your biggest compliance challenge
of European banks have identified between 20 to 30 CIFs within their organizations
46% of organizations identify the Register of Information (ROI) as their most challenging DORA requirement1. And this makes sense. At the heart of DORA compliance lies a comprehensive inventory of all your Critical or Important Functions. The European Banking Authority defines a CIF as any function whose disruption would materially impair financial performance, service continuity, or regulatory compliance. Straightforward in theory. Complex in practice.
Why CIF identification is harder than it sounds
A single payment processing function doesn't exist in isolation. It depends on customer authentication systems, fraud detection engines, network infrastructure spanning multiple data centers, cloud-based analytics platforms, and dozens of third-party service providers. Each dependency represents a potential failure point that DORA expects you to document, monitor, and continuously test. Once a function is classified as a CIF, it triggers cascading obligations:
- Enhanced oversight of third-party providers
- Mandatory contractual provisions specifying performance requirements
- Mandatory inclusion in your digital operational resilience testing program
- Continuous monitoring and real-time evidence of control effectiveness
Here's where the complexity really comes in.
64% of European banks have identified between 20 to 30 CIFs within their organizations2. Each CIF could depend on 50-100 ICT services. Each service might involve 5-10 control domains. Suddenly, you're managing visibility into thousands of control-service-function dependencies and expected to provide real-time evidence of control effectiveness across all of them.
The organizations embedding CIF awareness into governance frameworks, metrics, and daily operations are the ones achieving sustainable DORA compliance and genuine operational resilience. Everyone else is left drowning in spreadsheets.
[1] Deloitte European DORA Survey, 2025
[2] Deloitte European DORA Survey, 2025
identify the ROI as their most challenging DORA requirement
Strategic steps to overcome this blocker
1. Establish CIF-aligned governance
Once you've identified your CIFs, embed them into your governance framework - not as an IT or security issue, but as a business priority with clear executive accountability.
Develop CIF-specific metrics that roll up to board reporting, including control effectiveness scores and third-party performance indicators.
Assign ownership of each CIF to business leaders who understand the operational implications, creating an escalation pathway that connects CIF risk to executive decision-making.
2. Automate asset and dependency mapping
Modern asset discovery and dependency mapping tools create dynamic, continuously updated views of your technology estate rather than point-in-time snapshots created three months ago and now outdated.
The automation advantage extends to change management - when infrastructure changes occur, automated tools immediately identify which CIFs are affected, flagging potential new dependencies before they become control gaps.
3. Implement CIF-level analytics and reporting
For financial services organizations managing dozens of CIFs across complex technology estates, the ability to report control effectiveness at the CIF level is operationally essential.
With CIF-level fanalytics, you transform regulatory conversations from generic security metrics ("Our control effectiveness is 87%") to specific, CIF-aligned evidence ("Our payment processing CIF has 94% control coverage with three open remediation items, all addressed within 30 days").
This granular visibility is what regulators are actually looking for during supervisory visits.