The Regulatory Crossroads of 2025: DORA in Force, ePrivacy Hits Pause

At Elevate Partners, we support clients across a wide range of industries  -including financial services, energy, technology, and the public sector – in sourcing the right talent to meet emerging regulatory demands. From permanent risk and compliance managers to interim specialists in cyber resilience and privacy governance, our recruitment expertise spans the full spectrum of regulatory need.

DORA Enforcement: A New Era of Talent Requirements

Clarity in Compliance, Urgency in Hiring

DORA is now fully enforceable and applies across a broad spectrum of regulated entities, with direct implications for financial institutions, insurers, critical infrastructure, and their ICT service providers. It introduces a unified set of ICT risk management obligations, but its most immediate impact is on organisational structures and staffing needs.

Firms across sectors are now building out digital resilience functions that span legal, IT, compliance, cybersecurity, procurement, and internal audit. The knock-on effect has been the emergence of a new category of talent requirements that combine regulatory literacy with cross-functional technical awareness.

This has led to an urgent need for both permanent hires and short-term regulatory contractors who can hit the ground running. Many organisations are layering in contractors to execute risk assessments and compliance programmes in parallel with permanent team expansion.

In-Demand Roles Driven by DORA:

• ICT Risk & Controls Managers
• Third-Party Risk Managers
• Compliance Leads (with operational risk exposure)
• Legal Counsel (ICT Contracting and Subcontracting)
• Cyber Resilience Testing Specialists
• Contract Compliance Consultants for readiness assessments

These roles are being filled not only within traditional financial institutions, but also in energy, utilities, and public sector bodies where operational resilience and digital infrastructure security are becoming equally critical.

The introduction of new contractual obligations under DOR – such as audit rights, exit strategies, and subcontracting oversight – has triggered demand for legal and commercial professionals with experience drafting and reviewing ICT outsourcing agreements. Firms are increasingly seeking legal counsel who can advise across both DORA and NIS2 obligations, making these hybrid professionals especially valuable in today’s market.

At the same time, many organisations are investing in operational risk roles with a cyber edge. Candidates with exposure to both incident response planning and regulatory compliance are particularly attractive for companies trying to future-proof against ICT-related disruption.

Recruitment Implications of the ePrivacy Regulation Pause

Regulatory Uncertainty = Strategic Talent

The indefinite pause of the ePrivacy Regulation has resulted in a fragmented enforcement landscape across Europe, particularly for industries handling high volumes of user data. This has prompted organisations in e-commerce, media, telecoms, education, and healthcare to bolster their internal data governance capacity.

As a result, we are seeing increased demand for contract and interim privacy professionals who can advise on cookie compliance, marketing permissions, and cross-border consent standards. These roles are increasingly hired on a project basis to build adaptable consent frameworks, privacy impact assessments, and documentation ahead of future regulatory shifts.

Strategic Roles Emerging from the ePrivacy Gap:

• Privacy Engineers and Architects
• Interim Data Protection Officers (DPOs)
• Marketing Compliance Leads
• Senior Privacy Consultants
• Cookie Compliance Specialists

We’re also seeing companies invest in internal privacy champions – individuals embedded within marketing, product, or data teams to act as an early-warning system for regulatory risk. These hires reflect a growing maturity in how organisations view privacy – not just as a legal issue, but as a business-critical differentiator.

How Regulation Is Reshaping Compliance Structures

The disconnect between DORA’s clarity and ePrivacy’s ambiguity has pushed many firms across sectors to adopt more resilient and dynamic compliance models. These include:

• Appointing Regulatory Transformation Leads
• Splitting compliance into domains: tech risk, ESG, privacy, legal audit
• Creating dedicated interim teams for short-term delivery
• Investing in shared services models to scale governance across business units
• Embedding compliance professionals into technology, product, and operational teams

Forward-looking companies are treating compliance as a horizontal capability rather than a vertical silo—one that touches every part of the organisation, from procurement to customer experience.

Hiring Outlook by Function in 2025

Legal & Contracting:

Legal teams are hiring professionals with regulatory contracting experience, particularly those skilled in vendor oversight and ICT outsourcing across any regulated industry. These roles are often project-based, supporting regulatory implementation, contract remediation, or audits. We’ve also seen a rise in interim legal consultants brought in to review third-party supplier agreements.

Compliance:

Hiring is on the rise across energy, healthcare, technology, and finance. Demand spans both generalist compliance officers and niche experts in areas like DORA, ESG, and operational resilience. Many firms are building hybrid permanent-interim models, bringing in contractors to accelerate change while upskilling permanent teams.

Cybersecurity & Tech Risk:

Hiring is accelerating in sectors like energy, utilities, and telecoms, where ICT disruption has significant operational impact. Contractors with DORA, NIS2, ISO27001, or critical infrastructure experience are particularly in demand. Cyber GRC (governance, risk, and compliance) specialists are bridging technical risk and regulatory compliance.

Privacy & Data Governance:

Retail, education, digital platforms, and public sector bodies are all increasing their investment in data protection talent – especially those who can create jurisdictionally compliant digital experiences. Contract DPOs and privacy consultants are being used to scale quickly without long-term headcount commitments.

Compliance Talent Strategy: A Competitive Advantage

Leading organisations – regardless of sector – are using regulatory change as an opportunity to reimagine compliance. We’re seeing:

• Sector-agnostic secondments and contract pools for regulatory projects
• Building multi-disciplinary teams that include lawyers, data scientists, and operational risk experts
• Recruiting contract professionals to embed temporary resilience while upskilling permanent staff
• A shift from siloed compliance to enterprise-wide governance capabilities
• Use of internal mobility programmes to train up future regulatory leaders

Organisations that treat compliance as a strategic enabler – not a cost centre – are better placed to weather regulatory shifts and adapt to change.

How Elevate Partners Can Help

• We have a proven track record of supporting clients across all regulated sectors with:
• Permanent and interim placements in compliance, risk, legal, cyber, and data governance
• Contract recruitment for urgent programme needs or regulatory deadlines
• Specialist searches across tech risk, ESG compliance, operational resilience, and privacy
• Talent mapping, pipelining, and succession planning for long-term readiness

Our clients range from listed multinationals and public utilities to scale-up technology firms and government bodies. We understand that each sector has its own regulatory context – but the core challenge is the same: finding the right people to make compliance work.

Whether you’re preparing for a regulatory review, launching a compliance transformation programme, or navigating a complex cross-border data environment, Elevate Partners can help you build the right team.

Get in touch to learn more about how we can support your compliance hiring strategy in 2025 and beyond.

Elevate Partners – Experts in Permanent, Contract, and Interim Risk & Compliance Talent