Where do DORA and DSA overlap?

In 3 article-level pairings recorded in the Fontvera corpus. The table above lists each pair with the specific articles and a plain-language description.

Where do DORA and DSA conflict?

In 0 article-level conflicts. The most concrete ones are summarised in the Conflicts explained section.

Which regulation prevails in a conflict between DORA and DSA?

Neither regulation resolves the conflict on its face. Conflicts are typically resolved by the more specific provision or by regulator guidance — a legal-judgement call, not a mechanical rule.

§ DORA · DSA COMPARISON

DORA vs DSA: Where They Overlap and Conflict

3 overlaps, 0 conflicts and 2 gaps mapped between DORA and DSA in the Fontvera regulatory corpus.

Summary

DORA and DSA both apply across European business activity, but they were drafted at different times with different policy goals. This page summarises every article-level crossref between the two in the Fontvera corpus.

3 overlaps mean the same conduct triggers obligations in both regimes — design controls once, document twice. 0 conflicts mean the two regulations push in opposite directions on a specific question. 2 gaps mean one regulation leaves something on a topic the other addresses.

Who this applies to

Compliance teams who need to map a single control framework onto both DORA and DSA.

Compliance deadline

§ Detail

In depth

Summary statistics

Overlaps: 3 · Conflicts: 0 · Gaps: 2

5 article-level crossrefs catalogued between DORA and DSA from the Fontvera EU regulatory corpus. Article numbers are verbatim from the underlying obligation_crossrefs table; descriptions are extracted, not paraphrased.

All crossrefs between these regulations

Article (A)	Article (B)	Type	Severity	Description
DORA Art 14	DSA Art 11	overlap	low	[entity affected: Financial entities providing online platforms] Both regulations require entities to designate specific points of contact for communication with authorities and stakeholders during in
DORA Art 17	DSA Art 16	overlap	low	[entity affected: Financial entities providing hosting services] Both regulations require the establishment of mechanisms to receive, process, and act upon notifications or reports regarding incidents
DORA Art 14	DSA Art 17	overlap	low	[entity affected: Financial entities providing hosting services] Both regulations mandate clear communication and provision of reasons to affected parties (clients/recipients) regarding actions taken
DORA Art ?	DSA Art ?	gap	medium	[entity affected: Financial entities using AI for content moderation] Neither regulation explicitly addresses the intersection of ICT resilience testing for AI-driven content moderation systems, creat
DORA Art ?	DSA Art ?	gap	medium	[entity affected: Cross-border financial platforms] There is no clear guidance on how to reconcile DORA's strict incident notification timelines with DSA's requirement for user-friendly, non-technical

Overlaps explained

No conflict-type crossrefs were catalogued for this pair, but the 3 overlaps below mean a single control can be designed to satisfy both regulations at once. Plan the controls jointly to avoid duplicate effort:

DORA Art 14 vs DSA Art 11 (low severity) — [entity affected: Financial entities providing online platforms] Both regulations require entities to designate specific points of contact for communication with authorities and stakeholders during incidents or for general regulatory compliance.
DORA Art 17 vs DSA Art 16 (low severity) — [entity affected: Financial entities providing hosting services] Both regulations require the establishment of mechanisms to receive, process, and act upon notifications or reports regarding incidents or illegal content.
DORA Art 14 vs DSA Art 17 (low severity) — [entity affected: Financial entities providing hosting services] Both regulations mandate clear communication and provision of reasons to affected parties (clients/recipients) regarding actions taken during incidents or content moderation.

Which regulation takes precedence

EU law does not lay down a universal precedence rule between DORA and DSA. In practice three resolution approaches apply: lex specialis (the more specific provision wins when both purport to govern the same conduct); regulator guidance (EDPB, EBA, ESMA and the AI Office have all issued joint readings on overlapping articles — check the most recent applicable opinion); and document the choice (when the regulations leave the call to the controller, the audit defence is your written reasoning, not the regulator's silence). Where the corpus surfaces a conflict rather than an overlap, treat that as an escalation path to legal — not a control-design question.

What this means for your compliance team

Treat the 3 overlaps as design opportunities — one control, two regulatory anchors. Treat the 0 conflicts as escalation paths to legal: the regulations themselves don't resolve them, you do, and you document the reasoning. The 2 gaps point at scenarios where one regulation is silent while the other speaks — assume the regulator who has the explicit rule will win.