DORA and fintech compliance recruitment. Why are specialists so hard to find?

Financial regulation is increasingly overlapping with rules on technology, cybersecurity and operational resilience. For fintech companies operating at the intersection of finance and technology, this means recruiting professionals with a much broader range of expertise. As a result, building compliance and AML teams has become one of the industry’s most difficult hiring challenges.

One role, several fields of expertise

DORA (Regulation (EU) 2022/2554) has applied throughout the European Union since 17 January 2025. Since then, all of its requirements have been fully enforceable. The regulation places obligations on financial institutions relating to ICT risk management, oversight of technology providers and the reporting of major incidents.

In banks, technology is one of the systems supporting financial operations. In fintech, it is the foundation of the entire business model. Technology risk therefore translates directly into operational risk. Compliance professionals increasingly need to understand not only financial regulation, but also the fundamentals of technology risk management.

A shrinking talent pool

AML professionals typically build their careers on a legal or financial education, supported by industry certifications. This is already a relatively narrow and specialised career path. Adding knowledge of technology and operational regulation to the requirements reduces the number of available candidates even further.

The person being hired needs to understand both the logic of financial law and the fundamentals of ICT risk management. This combination of skills remains relatively rare in the talent market.

“There are very few candidates worldwide who combine AML experience, an understanding of technology risk and practical experience in financial services. In most fintech recruitment projects, we therefore look for someone who is particularly strong in one of these areas and then work with the client to determine how the remaining skills can be developed or supplemented,” explains Katarzyna Szudy, General Manager at HR Contact.

The challenge is intensified by the market’s rapid growth. According to the Polish FinTech Map, the number of active fintech companies in Poland increased from 167 in 2018 to 376 in 2026. The sector now employs more than 22,000 specialists.

However, the growing demand for experts has not been matched by equally rapid changes in education. Law and computer science have long ranked among the five most popular fields of study in Poland – in the 2025/2026 academic year, each attracted more than 26,000 applicants. Yet they remain two separate educational paths, usually chosen by different people.

Only a small number of professionals enter the market with both financial regulatory knowledge and a practical understanding of technology and ICT risk management. Most employers also expect direct experience in financial services, narrowing the candidate pool even further.

How can fintech companies respond?

Dividing responsibilities between AML specialists and professionals responsible for technology compliance makes sense in large organisations, where the scale of operations and available budget justify this structure. Smaller fintech companies, however, can rarely afford to build several specialised teams.

“For companies that are still scaling, a more realistic solution is to broaden existing AML roles to include operational and technology regulation. In areas that require highly specialised technical knowledge, such as assessing the security of ICT providers, they can draw on external experts, law firms or consultants,” explains Katarzyna Szudy, General Manager at HR Contact.

For employers, this requires a different approach to fintech compliance recruitment. In a rapidly changing regulatory environment, the ability to develop skills within the organisation may be more important than finding an “ideal” candidate who meets every requirement from day one.

In practice, fintech companies will increasingly need to decide which skills are essential at the start and which can be developed on the job or supplemented with support from external partners.

FAQ – fintech compliance recruitment

When did DORA start applying to fintech companies in Poland?

DORA (Regulation (EU) 2022/2554) has applied since 17 January 2025. It covers credit institutions, payment institutions, electronic money institutions, crypto-asset service providers and third-party ICT service providers supporting the financial sector. The entity’s management body bears direct responsibility for correct implementation.

Why is it so difficult to find AML specialists with DORA expertise?

AML career paths are usually based on a legal or financial education. ICT risk management is a separate, technical discipline. Professionals who combine both areas are rare, and most employers also require direct experience in financial services – narrowing the talent pool even further.

How do you recruit when the ideal candidate does not exist?

Start by deciding which skills are essential from day one and which can be developed on the job. In practice, it can be more effective to hire someone who is particularly strong in one area – either AML or ICT risk – and plan how the remaining capabilities will be developed internally or with the support of a recruitment partner that understands the fintech sector.

Summary

DORA and the growing volume of technology regulation have permanently changed the profile of a fintech compliance specialist. The market is no longer looking for a purely legal or purely technical professional – it needs someone who can understand both worlds. There are few candidates with this combination of skills, and the education system is not keeping pace with the rate of change.

For fintech companies, effective compliance recruitment is no longer about waiting for the “ideal” candidate. It depends on identifying the critical skills accurately and planning how the remaining capabilities will be developed. A recruitment partner that understands both financial regulation and the technology context can make a tangible difference in this process.

If you are building a compliance or AML team in the fintech sector and need specialists who combine regulatory expertise with an understanding of technology, talk to HR Contact.