EVIDENTIARY GOVERNANCE Jean-François ELSEN EVIDENTIARY GOVERNANCE Jean-François ELSEN

SOURCE 0 - THE DORA NOTIFICATION PARADOX

DORA requires a bank to prove when it became aware of an incident and when it classified it as major — the two instants a regulator disputes most. Both are written exclusively by the bank itself. This article examines why TLPT, Article 6 internal audit, and third-party oversight do not supply an independent witness to either instant, and what a pre-execution, third-party-deposited fixation adds to the DORA timeline.

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