Last updated: 5 August 2026.
Quick answer. Under the Digital Operational Resilience Act (DORA), ICT services are digital and data services provided through ICT systems to one or more internal or external users on a continuous basis, covering software, hardware, networks and other data processing and storage services. Within this taxonomy, free-to-air transmission services — instant messaging, email and VoIP — operate without allocated network resources or telephone numbers, while electronic communications services form a broader regulatory category consisting of the transmission of signals over electronic communications networks. Traditional analogue services such as PSTN, POTS and fixed telephony fall outside DORA’s digital focus.
In the dynamic landscape of European financial regulation, the Digital Operational Resilience Act (DORA) has introduced a series of concepts and definitions that warrant thorough analysis. In this post, we delve into the intricate taxonomy of Information and Communication Technology (ICT) services within the context of DORA, exploring their various categories and exclusions.
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ICT Services under DORA: The Digital Backbone of the Financial Sector
DORA defines ICT services as digital and data services provided through ICT systems to one or more internal or external users on a continuous basis. These services encompass software, hardware, networks, and any other form of data processing and storage services. In essence, they constitute the technological foundation upon which the operational infrastructure of the modern financial sector is built.
Free-to-Air Transmission Services: The New Frontier of Communications
Within the ICT services ecosystem, we encounter so-called free-to-air transmission services. These refer to communication services that do not rely on the allocation of specific network resources or telephone numbers. They include instant messaging applications, email, and voice-over-IP (VoIP) services. Their distinctive feature is their flexibility and independence from traditional telecommunications infrastructure.
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Electronic Communications Services: The Regulatory Umbrella
Electronic communications services comprise a broader category that includes free-to-air transmission services. According to European legislation, these services consist of the transmission of signals over electronic communications networks. They encompass Internet access services, interpersonal communications services, and services which consist wholly or mainly in the conveyance of signals.
Exclusion of Analog Services: PSTN, POTS, and Fixed Telephony Services
It is essential to understand that DORA, in its focus on digital resilience, expressly excludes certain categories of traditional analog telephony services. These include:
- Public Switched Telephone Network (PSTN): The traditional circuit-switched telephony infrastructure.
- Landline Services: Physical telephone connections using copper wiring.
- Plain Old Telephone Service (POTS): The basic telephone system that has existed since the early days of telephony.
- Fixed Telephony Services: Telephone lines tied to a specific physical location.
These exclusions reflect DORA’s emphasis on modern digital services, acknowledging that traditional analog systems operate under different risk and resilience paradigms.
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Frequently asked questions
DORA defines ICT services as digital and data services provided through ICT systems to one or more internal or external users on a continuous basis. They encompass software, hardware, networks and any other form of data processing and storage services, and constitute the technological foundation of the operational infrastructure of the modern financial sector.
They are communication services that do not rely on the allocation of specific network resources or telephone numbers, such as instant messaging applications, email and voice-over-IP (VoIP) services. Their distinctive feature is their flexibility and their independence from traditional telecommunications infrastructure.
Electronic communications services are a broader category that includes free-to-air transmission services. Under European legislation, they consist of the transmission of signals over electronic communications networks and encompass Internet access services, interpersonal communications services and services consisting wholly or mainly in the conveyance of signals.
No. In line with its focus on digital operational resilience, DORA excludes analogue services such as the public switched telephone network (PSTN), plain old telephone services (POTS) and fixed-line telephony from its concept of ICT services.
Because they form the digital backbone on which the operational infrastructure of the modern financial sector is built: the software, hardware, networks and data processing and storage services that financial entities rely on continuously to operate.
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Related tool, free to use: the financial regulation tools.
