The answer to this question is provided by the European Commission.

As outlined in recital 8 DORA, DORA’s principal objective is to develop the Single Rulebook regulating the Union financial sector and the system of supervision to also cover digital operational resilience, by strengthening the mandates of competent authorities to enable them to supervise the management of ICT risk in the financial sector in order to protect the integrity and efficiency of the internal market, and to facilitate its orderly functioning. Therefore, as recalled by recital 105 DORA aims to achieve a high level of digital operational resilience for regulated financial entities. In light of the above, the framework introduced by DORA is to be considered an horizontal financial legislation that complements the Union sectorial financial legislations with regard to entities regulated under those legislations.

Article 2(1)(o) DORA specifies that ancillary insurance intermediaries are within the scope of DORA. Article 3(50) DORA defines ancillary insurance intermediaries by referring to the definition under Article 2(1), point (4) of Directive (EU) 2016/97 (“IDD”). Article 1(3) IDD exempts from the application of IDD certain ancillary insurance intermediaries carrying out insurance distribution activities provided that they meet the conditions laid down in that article. Consequently, these insurance intermediaries are not regulated under IDD and therefore do not have to register in virtue of IDD with a competent authority in their home Member State. In view of the objective of DORA which is to complement the Single Rulebook to ensure the ICT resilience of regulated financial entities, the definition of “ancillary insurance intermediary” under DORA is to be understood as not covering the ancillary insurance intermediaries that are exempted from the application of IDD pursuant to Article 1(3) IDD.

Disclaimer provided by the European Commission:

The answers clarify provisions already contained in the applicable legislation. They do not extend in any way the rights and obligations deriving from such legislation nor do they introduce any additional requirements for the concerned operators and competent authorities. The answers are merely intended to assist natural or legal persons, including competent authorities and Union institutions and bodies in clarifying the application or implementation of the relevant legal provisions. Only the Court of Justice of the European Union is competent to authoritatively interpret Union law. The views expressed in the internal Commission Decision cannot prejudge the position that the European Commission might take before the Union and national courts.