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Benchmarking Third-Party Performance

Benchmarking ICT provider performance under DORA: comparing service, cost and resilience against peers and past performance, and recognising what a benchmark cannot prove.

Published 26 October 2026Checked against the regulation text on 26 October 2026European Union (financial entities in scope of DORA)

The short answer

Benchmarking third-party performance means comparing a provider's service, cost and resilience against relevant comparators, such as its own past performance, alternative providers, or market practice for a similar function. Under DORA, benchmarking is a useful oversight tool because it challenges complacency: a provider that meets its contract may still be falling behind what comparable arrangements achieve. Benchmarking does not, on its own, prove that a provider is safe or unsafe. It produces questions and evidence for discussion, renegotiation or redesign, and its value depends entirely on whether the comparison is fair, current and relevant to the service in question.

What is actually being compared?

A market data feed illustration shows why the object of comparison must be defined. Two feeds might both claim broad coverage, yet differ in timeliness, completeness, resilience arrangements and support quality. Comparing headline price alone would miss those differences, while comparing every feature without weighting them would produce noise. Useful benchmarking therefore starts by naming the dimensions that matter for this service: reliability, recovery capability, support responsiveness, security posture in broad terms, and cost structure. Each dimension can then be compared on evidence, rather than on marketing claims or on a single headline figure.

Which comparators make sense?

Comparators should resemble the service being benchmarked, or the comparison will mislead. A provider supporting a small, specialised function cannot fairly be judged against a global platform serving a different market, and a provider's current performance cannot fairly be judged against its own performance in a period when the service was far smaller. Internal comparison over time is often the most reliable starting point, because the service and the expectations are constant. External comparison adds value where a genuine alternative exists and where data about that alternative is credible, such as through market engagement or independent sources, rather than through a competitor's sales material alone.

Why does benchmark data need care?

Benchmark data needs care because providers report performance differently, and because averages can hide the experiences that matter. A provider might report strong average availability while suffering repeated short outages that disrupt a particular service at peak times. A cost benchmark might compare unlike scopes, such as a service that includes support and recovery against one that charges separately for them. The entity should therefore ask how each figure was defined, over what period, and for which scope, before drawing conclusions. A benchmark built on unlike definitions is worse than no benchmark, because it gives a false sense of precision. Asking for definitions before comparing figures is therefore a basic step, not an optional refinement for specialists.

How should benchmarking results be used?

Benchmarking results are best used as an input to judgement, not as an automatic trigger. A provider that lags peers might be asked for an improvement plan, offered renegotiated terms, or given enhanced monitoring. A provider that leads peers might still warrant attention if its cost structure creates concentration or if its service has become difficult to replace. The response should be proportionate to the service: a minor gap for a routine tool calls for a conversation, while a significant gap for a provider supporting an important service calls for a documented plan with follow-up. Recording the decision and its reasons keeps benchmarking honest, since it prevents results from being cited selectively later.

What can benchmarking not do?

Benchmarking cannot replace oversight, audit or exit planning, and it cannot answer whether a provider will perform during a severe disruption. Market comparison describes normal conditions well and extreme conditions poorly, because few benchmarks capture how a provider behaves when its own systems are under stress. Benchmarking also cannot capture relationship quality, such as whether a provider communicates openly during an incident, except indirectly through the entity's own experience. Treating benchmarking as one lens among several, alongside reporting, audit and incident experience, keeps it in proportion and prevents a favourable benchmark from becoming a substitute for assurance.

Primary sources on the record

Legal status: Regulation (EU) 2022/2554 in force; applies from 17 January 2025, with technical standards applying on the dates stated in each standard. Application position for this topic: Applies from 17 January 2025. Technical standards apply on their own stated dates.

Follow the service map

Line 09 - ICT third-party risk ICT Third-Party Risk Management A DORA guide to ICT third-party risk as one chain from selection to exit, showing why a supplier dependency stays with the financial entity throughout the contract. Line 09 - ICT third-party risk Third-Party Risk Registers What a third-party risk register is under DORA: a current, service-linked record of providers and risks that supports oversight, incident response and exit, not a list for its own sake. Line 09 - ICT third-party risk When a Supplier Becomes Critical How a supplier becomes critical under DORA: not always by appointment at signing, but by drift, growth and concentration, until a service cannot run or recover without it.