Home Insights & AdviceThe DORA Domino: Why London law firms are losing clients

The DORA Domino: Why London law firms are losing clients

by Sarah Dunsby
1st Jun 26 9:14 am

Every year, London law firms spend millions hardening their case management systems, vetting their cyber insurers, and briefing partners on data privacy. None of it matters if sensitive transaction terms are being negotiated over WhatsApp or Signal.

That is not a hypothetical. It is the operational reality at hundreds of UK legal practices right now — and it is about to become a commercial liability of the first order.

The European Union’s Digital Operational Resilience Act (DORA) came into full force in January 2025. Its reach extends well beyond the banks and insurers it nominally governs. Law firms that act as technology vendors in the deal ecosystem now sit squarely in its firing line — and the window to act is closing.

The compliance assumption that will cost firms clients

Since GDPR came into effect in 2018, the prevailing attitude across the City has been that data compliance is a solved problem. Firms updated their privacy notices, appointed data protection officers, and moved on. The assumption was reasonable at the time. It is now dangerously outdated.

DORA does not care about privacy notices. It cares about operational resilience — the technical and mathematical ability of an organisation to withstand, document, and recover from severe cyber disruptions in real time.

That distinction matters enormously. GDPR governs what happens to data after a breach. DORA governs whether your infrastructure is architecturally capable of preventing one in the first place. The two frameworks do not overlap. Passing one audit gives you no credit on the other.

For law firms, the immediate consequence is this: any practice that relies on general-purpose cloud tools — Microsoft 365, Google Workspace, Slack, Dropbox, or WhatsApp — for sensitive client communications is running infrastructure that fails a DORA-grade technical review by design. These platforms were not built for the resilience standards DORA mandates.

Why your firm is in the crosshairs

DORA’s most commercially consequential provision is its Third-Party ICT Risk Management framework. Financial institutions — the investment banks, private equity funds, and institutional underwriters that constitute the City’s most lucrative legal clients — are legally required to audit the digital infrastructure of every key vendor they engage. Law firms providing legal services on active transactions are classified as key vendors.

If a law firm cannot demonstrate that its communication and document-sharing infrastructure meets DORA’s resilience standards, its financial institution clients are legally barred from continuing that engagement. This is not a reputational consequence. It is a binary commercial one.

The attack vector this addresses is well established in cybersecurity. Financial institutions have invested billions in hardening their own perimeters. Adversaries have adapted accordingly — targeting the supply chain instead. During a major acquisition or restructuring, millions of pounds worth of privileged deal terms, financial metrics, and litigation strategy flow through external legal counsel. That flow is the vulnerability.

The specific risks of general-purpose cloud tools

The legal sector’s dependence on consumer-grade productivity software is understandable. These tools are fast, familiar, and free at the point of use. The hidden costs are technical, and they are severe.

Standard enterprise cloud platforms — including Microsoft 365 and Google Workspace — do not utilise zero-knowledge encryption. The service provider retains the master encryption keys. This means that files stored on these platforms are, in principle, readable by the cloud host and accessible to foreign governments under legislation such as the US Stored Communications Act, without the knowledge or consent of the data subject.

The problem has been compounded by the recent integration of generative AI features directly into these platforms. Microsoft Copilot and Google Gemini are trained and refined using interaction data. Confidential deal communications, privileged legal advice, and commercially sensitive transaction documents processed through these tools may, depending on enterprise licensing terms, contribute to model training. The implications for attorney-client privilege are not theoretical — they have been the subject of formal guidance from the Law Society.

WhatsApp and Slack present a further category of risk. Neither platform was designed for regulated professional communication. Access controls are informal, audit trails are incomplete, and message deletion is unilateral. When a link to a confidential document is forwarded from a group chat, there is no trace of who received it. There is no mechanism to revoke access retroactively. In a regulatory investigation, that absence of audit trail is itself evidence of governance failure.

What a compliant architecture actually looks like

The solution is not a more carefully configured version of the tools firms already use. It is a purpose-built private deal room designed from the ground up for privileged legal communication.

Qaxa is an end-to-end encrypted collaboration platform built specifically for legal professionals. It consolidates the functions of a document repository, secure messaging channel, and deal management workspace into a single, zero-knowledge environment where your organisation retains absolute data sovereignty. Because encryption keys are generated and held exclusively on the client side, your data remains fully shielded from third-party infrastructure providers, cloud hosts, and government subpoenas issued under foreign jurisdictions.

When file repositories, real-time messaging, and task management operate under a single cryptographic architecture, the result is categorical: neither the software developer nor the cloud host can read the contents. If a regulatory body or hostile actor attempts to access the files, all they will ever encounter is unreadable ciphertext.

This structural guarantee does more than satisfy a compliance audit. It shifts a firm’s classification in its clients’ vendor risk frameworks from ‘vulnerable third-party’ to ‘certified secure partner.’ For firms competing for institutional mandates, that reclassification is a direct revenue differentiator.

The practical transition is less disruptive than it appears. Qaxa’s interface consolidates the functions that legal teams currently distribute across four or five separate platforms. The efficiency gain alone has been cited by early adopters as sufficient justification for the switch, independent of the compliance benefit.

Compliant today, competitive tomorrow

General-purpose tools were built for convenience, not for the protection of privileged communications. Using them for sensitive deal work is no longer a calculated risk — it is an unpriced liability sitting on every client engagement.

Regulators are enforcing, institutional clients are auditing, and insurers are repricing. None of those pressures is reversing. The firms that act now to establish a secure private deal room infrastructure will hold a durable advantage. The ones that defer will be left explaining the delay to clients who have already moved on.

To secure your firm’s most critical communications under zero-knowledge architecture, visit [Qaxa.com].

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