This article makes repeated references to RTS's while forgetting to mention the absolute most important caveat. RTS's are not law. They're selectively delegated to in the law, but they are themselves not enforcable. What that means in practice is that ANY reference to an RTS MUST include an analysis of if the recomendation is mandated by the actual law (in this case DORA).

This is absolutely critical to understand for anyone dealing with these laws. The RTS's are allowed, and expected, to include provisions that are not enforcable because they fall outside the mandate delegated from the sponsoring law.