Relying on a vendor's AI agent platform puts DORA's ICT third-party risk rules on you at three stages. Before signing: a strategy and policy, pre-contract assessment, due diligence and, for critical functions, notifying your supervisor. While live: monitoring, audit, the register and change control. At the end: termination rights and a tested exit. Each stage must leave evidence.
What does DORA require on ICT third-party risk, in plain words?
DORA (Regulation (EU) 2022/2554), applying from 17 January 2025, treats ICT third-party risk as part of ICT risk management. The financial entity remains fully responsible for compliance whatever it outsources. In substance, it must:
- adopt a strategy on ICT third-party risk and a policy on the use of ICT services supporting critical or important functions, approved and reviewed by the management body;
- before contracting, assess whether the service supports a critical or important function, check supervisory conditions are met, identify and assess risks including concentration, carry out due diligence on the provider and assess conflicts of interest;
- inform the competent authority of planned arrangements covering critical or important functions;
- include required contract terms;
- keep a register of information on all ICT third-party arrangements;
- monitor providers' performance and risk, using audits and other assurance, on a risk basis;
- be able to terminate in defined circumstances and keep exit strategies for critical or important functions.
The general position that agent providers are ICT third parties is set out in DORA makes agent providers your ICT third parties.
Who does this apply to?
Financial entities within DORA's scope that use an ICT third-party service provider, which includes an agent vendor running agents on its platform for them. The edge cases, such as open-source agent libraries or model access through an intermediary, are covered in are AI agent vendors ICT third-party providers under DORA.
What should you do before relying on the platform?
Due diligence on an agent platform needs questions a normal software review would not ask. Which model providers does the platform use, and can it switch them without telling you? Where do inference and storage happen? Who holds the record of what agents did, and in what format? Can you set and verify each agent's permissions, or only request them? What has the vendor done to resist injected instructions in the content agents read?
The vendor's assurance reports, such as a SOC 2 report or an ISO/IEC 27001 certificate, tell you about its general controls. They do not tell you how its agent behaves on your cases within your limits. Run your own test on a sample of your real past work before relying on the platform, and file the results with the due diligence. US groups will recognise the same principle from SR 11-7 vendor models and third-party agents: the vendor's validation does not replace yours.
What should you do while it is live, and at the end?
While live, monitor on three levels: the vendor's service levels and incidents; the agent's behaviour in your operation; and changes to the vendor's set-up, especially model changes. Audit on a risk basis. Keep the register current. Review the arrangement at a set interval and whenever something material changes.
At the end, the contract must let you terminate in the circumstances DORA lists, with a transition period, and the exit strategy must let you leave without losing service or records.
| Requirement | Control | Evidence it leaves |
|---|---|---|
| Strategy and policy | Management body approves third-party strategy and policy covering agent platforms | Approved documents and review minutes |
| Pre-contract assessment | Classify function supported; assess risks and concentration | Assessment record |
| Due diligence | Review vendor controls, model providers, data location, record ownership; test the agent on your own cases | Due diligence file with your test results |
| Conflicts of interest | Check vendor relationships that could bias service or advice | Conflicts assessment |
| Notify the authority | Planned critical or important arrangements reported | Notification records |
| Contract terms | DORA terms plus model change notice, record export and right to test | Signed contract and schedules |
| Register of information | Arrangement and subcontractors recorded | Register entries |
| Ongoing monitoring | Service levels, behaviour metrics, change notices and audit results reviewed | Monitoring packs and audit reports |
| Termination and exit | Rights to terminate and a tested exit plan | Contract clauses and exit test |
An agent can help with this work, drafting due diligence summaries or tracking vendor changes, as discussed in can an AI agent assess third-party risk. The decision to rely on the vendor stays with people.
What will a supervisor ask?
- Show us the due diligence for your agent platform, including your own testing.
- Which model providers sit behind it, and how would you know if that changed?
- Did you classify the function it supports, and did you notify us?
- What monitoring tells you the agent still behaves as it did when you approved it?
- Have you audited the vendor, or relied on its reports alone?
- Where is the arrangement in your register?
What does the third-party duty not cover?
It does not transfer responsibility to the vendor. It does not dictate which vendors you may use, provided risk is managed. It does not cover non-ICT outsourcing, which sits under other rules. And it sits inside the wider DORA ICT risk management framework for AI agents, which must cover the agent itself as an asset. For the cross-regime map, see AI agent regulation mapped to controls.
This is an explanation of the rules, not legal advice; confirm how they apply to you with counsel.
Where Pryme fits
Pryme certifies each agent capability on the customer's own cases, which gives due diligence the evidence a vendor's general reports cannot. Certificates lapse after 90 days, so ongoing monitoring includes a fresh test of the agent's behaviour rather than relying on the result from the day you signed.
Questions people ask
Is the vendor's SOC 2 report enough due diligence?
It covers the vendor's general controls. DORA due diligence should also cover how the agent behaves in your operation, which needs your own testing.
How often should the arrangement be reviewed?
On a risk basis, with arrangements supporting critical or important functions reviewed more often, and immediately after material changes such as a new model provider.
Do pilots need the full process?
A pilot on real customer data or live systems is still an ICT arrangement. Scale the process to the risk, but do not skip due diligence or the register.