As risk advisers working closely with FinTech’s, we want to flag a major regulatory change that could significantly impact your business: the upcoming ODR (Operational Data Resilience) Legislation, taking effect in mid-2025.
This isn’t just another compliance box to tick—it’s a shift in the way FinTech’s will be expected to operate, manage risk, and protect consumers. For many forward-thinking FinTech’s, it’s also an opportunity to strengthen cyber resilience and revisit insurance strategies that may no longer be fit for purpose.
What Is the ODR Legislation?
Modelled on Europe’s DORA framework, Australia’s ODR legislation will require all digital financial service providers to prove they can withstand and respond to operational disruption. This includes:
- Robust system availability,
- Comprehensive data protection, and
- Formalised incident response capabilities.
In short, ODR introduces a new benchmark for operational and cyber resilience in the financial services ecosystem.
Why This Matters for Fintechs
Whether you’re in early growth or entering scale-up mode, ODR has real implications for your risk management and insurance program:
- Expanded insurance needs: Cyber, tech E&O, and business interruption cover must now extend to regulator scrutiny, data breach fallout, and third-party platform failures.
- Increased scrutiny on third-party dependencies: Your tech stack and partners are now part of your regulated risk profile.
- Rising insurance costs: largely due to heightened regulatory expectations and cyber exposure.
The gap between “good enough” insurance and ODR-ready coverage is widening. That’s where the right risk partner—and the right policy structure—can make a difference.
One Policy, Three Critical Sections
A tailored insurance solution many FinTech’s are adopting is a combined policy underwritten by a single insurer, with three core sections:
- Professional Indemnity for software developers and technology providers,
- Cyber Risk, and
This approach prevents gaps or unnecessary overlaps in cover, aligns terms and conditions across risk areas, and streamlines your protection with a single policy deductible. It also brings clarity and simplicity—critical when demonstrating resilience to regulators under ODR.
Three Actions You Should Be Taking Now
- Audit your current insurance policies for exclusions or shortfalls in cyber, crime, and tech E&O coverage.
- Map your operational and third-party risks—especially where client data and digital services intersect.
- Start the conversation early to build a risk strategy that supports compliance, resilience, and business continuity.
📩 Not sure where to start? Let’s connect for a Risk Conversation. We’ll walk you through how the ODR legislation may affect your business and what a proactive insurance strategy looks like in this new environment.
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Smart Decisions Faster.
At 4Sight Risk Partners, we protect what matters most, enabling you to move forward with confidence. Our team specialises in managing business risks and delivering world-class insurance solutions.
With over 75 years of global expertise, our proprietary IQ-ARTA Framework helps clients make informed decisions based on qualified risk profiles and quantified risks. By leveraging a global network of subject matter experts and leading insurers like Lloyd’s of London, we provide tailored solutions to address complex challenges across industries.
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Explore more at 4sightrisk.com.au or reach out to discuss how we can help you make smart decisions faster.
Gareth Jones
Managing Director
4Sight Risk Partners
[email protected]
0499 988 980
+61 499 988 980 if calling outside of Australia
Adviser Representative No: 1251287

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