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  <front>
    <journal-meta>
      <issn pub-type="ppub">1613-0073</issn>
    </journal-meta>
    <article-meta>
      <title-group>
        <article-title>Organizations: Requirements for a Modeling Framework</article-title>
      </title-group>
      <contrib-group>
        <contrib contrib-type="author">
          <string-name>Georgios Koutsopoulos</string-name>
          <email>georgios@dsv.su.se</email>
          <xref ref-type="aff" rid="aff0">0</xref>
          <xref ref-type="aff" rid="aff1">1</xref>
        </contrib>
        <contrib contrib-type="author">
          <string-name>Jakob Vannerus</string-name>
          <email>jakob@vannerus.com</email>
          <xref ref-type="aff" rid="aff0">0</xref>
          <xref ref-type="aff" rid="aff1">1</xref>
        </contrib>
        <contrib contrib-type="author">
          <string-name>Linus Karlsson</string-name>
          <xref ref-type="aff" rid="aff0">0</xref>
          <xref ref-type="aff" rid="aff1">1</xref>
        </contrib>
        <contrib contrib-type="author">
          <string-name>Franco Ivan Quinteros-Ureta</string-name>
          <xref ref-type="aff" rid="aff0">0</xref>
          <xref ref-type="aff" rid="aff1">1</xref>
        </contrib>
        <contrib contrib-type="author">
          <string-name>Workshop</string-name>
          <xref ref-type="aff" rid="aff1">1</xref>
        </contrib>
        <aff id="aff0">
          <label>0</label>
          <institution>Department of Computer and Systems Sciences, Stockholm University</institution>
          ,
          <addr-line>Stockholm</addr-line>
          ,
          <country country="SE">Sweden</country>
        </aff>
        <aff id="aff1">
          <label>1</label>
          <institution>Enterprise Modeling</institution>
          ,
          <addr-line>Requirement, Implementation, European Union, Act, Regulation, Framework</addr-line>
        </aff>
      </contrib-group>
      <abstract>
        <p>The increased complexity and frequency of regulations provided by the European Union creates a highly dynamic landscape for the organizations based within it. Implementing these regulations is a challenging task, especially in regard to their inherent complexity and specificity. The situation can be improved by Enterprise Modeling, yet, a domain-specific modeling framework cannot be developed before a structured set of requirements has been elicited for the artifact. In this study, a qualitative survey with semi-structured interviews has been conducted, splitting the focus between two specific acts, the DORA and EAA. The collected data have been subjected to thematic analysis, and the results have been used for the elicitation of a set of requirements, presented in the form of a goal model. Examples of the identified goals include regulatory clarity, resource allocation, training, and management support.</p>
      </abstract>
    </article-meta>
  </front>
  <body>
    <sec id="sec-1">
      <title>1. Introduction</title>
      <p>
        The European Union (EU) consistently develops and enforces legislation that its members states are
obliged to adhere to. These laws, commonly known as EU acts, aim to set standards, as a means
to harmonize the operational context and improve fairness for EU-based organizations [
        <xref ref-type="bibr" rid="ref1">1</xref>
        ]. A wide
spectrum of operational areas is covered by EU acts, for example, digital protection, addressed with the
General Data Protection Regulation (GDPR) [
        <xref ref-type="bibr" rid="ref2">2</xref>
        ], digital resilience, addressed with the Digital Operational
Resilience Act (DORA) [
        <xref ref-type="bibr" rid="ref3">3</xref>
        ], and the accessibility of products and services for people with disabilities,
addressed by the European Accessibility Act (EAA) [
        <xref ref-type="bibr" rid="ref4">4</xref>
        ]. A significant part of the acts’ content is
relevant to and addresses the digital aspect of the organizations. The digitalization of contemporary
organizations does not allow decoupling them from their information systems. On the contrary, it is
safe to assume that business and Information Technology (IT) are “fused” into one [
        <xref ref-type="bibr" rid="ref5">5</xref>
        ], which is an
essential aspect that defines modern organizations. This provides the opportunity to utilize academic
and industrial expertise derived from the area of Business Informatics and IT in general to improve the
complex task of implementing EU acts in organizations. Organizations that need to interpret and apply
EU acts to their unique operational context can be facilitated by a variety of disciplines.
      </p>
      <p>
        One such discipline that can provide eficient solutions to organizational challenges of high complexity
is Enterprise Modeling (EM) [
        <xref ref-type="bibr" rid="ref6">6</xref>
        ]. EM aims for the structured development of models that capture the
organization’s processes, resources, domain, goals, etc., as a means to analyze and improve the operations
of the enterprise [
        <xref ref-type="bibr" rid="ref6">6</xref>
        ]. Regarding EU acts, EM can help visualize the implementation and its impact,
identify gaps and omissions, and develop strategies to tackle identified gaps. EM approaches can be
generic or domain-specific, that is, they can be developed as a means to ad-dress problems of any type,
      </p>
      <p>CEUR</p>
      <p>ceur-ws.org
or be optimized for addressing problems of specific types and phenomena. EU act implementation can
be perceived as domain-specificity [ 7] for a modeling framework.</p>
      <p>From a Design Science Research (DSR) [8] perspective, a domain-specific modeling framework aiming
to tackle the above-mentioned challenge is an artifact. Every artifact needs to be developed based on
a set of requirements that outline and describe the artifact’s capabilities. For this reason, the goal of
this paper is to elicit a set of requirements for a modeling framework that will support the implementation
of EU Acts in organizations. Two specific instances of EU act implementations are used, DORA and
EAA, and experts have been interviewed to collect data and synthesize a set of goals for a modeling
framework artifact.</p>
      <p>The rest of the paper is structured as follows. Section 2 provides a brief overview of the related
background. Section 3 explains the involved methodological decisions, Section 4 presents the empirical
results of the study, Section 5 introduces a set of requirements derived from the results, and Sections 6
and 7 discuss and provide concluding remarks on the study, respectively.</p>
    </sec>
    <sec id="sec-2">
      <title>2. Background</title>
      <p>
        2.1. EU Acts
EU acts is a term commonly used to describe all the types of EU legislation. The EU has systematically
aimed for the standardization and harmonization of laws across its member states. EU legislation is
designed and published to ensure a consistent and fair operational context for EU-based organizations,
while in parallel promoting fairness for the EU citizens as customers of the organizations complying with
the regulations. They are classified into five main categories [ 9], which are (i) Regulations, which are
binding legislative acts that are applied directly to all member states without needing any transposition
or contextualization, (ii) Directives, which are applied to the member states indirectly, in other words,
every member state is allowed to devise their own laws for achieving the goals set by the directive,
(iii) Decisions, which are legally binding laws with direct application, yet, they do not apply to all
member states but have specific respondents, (iv) Recommendations, and (v) Opinions, which are both
non-binding laws that only serve as guidance for the EU’s member states. The entire repository of EU
legislation is available at the EUR-Lex portal [
        <xref ref-type="bibr" rid="ref1">1</xref>
        ].
      </p>
      <p>
        A wide spectrum of acts covers all the important legal topics across the member states. A few
examples are the GDPR [
        <xref ref-type="bibr" rid="ref2">2</xref>
        ], the recent Artificial Intelligence Act (AI act) [ 10], the DORA [
        <xref ref-type="bibr" rid="ref3">3</xref>
        ], and the
EAA [
        <xref ref-type="bibr" rid="ref4">4</xref>
        ]. Despite their diverse content, what is common among them is that their implementation is
challenging because of the detailed requirements that the EU-based organizations need to comply with.
      </p>
      <p>
        In this study, the main concern lies around the DORA and the EAA. The DORA is a legislation
that requires increased cyber-security measures in organizations of the financial sector, like banks,
or insurance and investment companies. Its aim is to reduce the vulnerability of EU-based financial
organizations against IT-related incidents, for example, cyber-attacks [
        <xref ref-type="bibr" rid="ref3">3</xref>
        ]. Its application dictates
investments in technology and adaptations in the organizations’ processes in order to fulfill the act’s
requirements. The EAA’s focal point is to ensure that products and services in EU member states are
accessible to individuals with disabilities. The EAA has a broad area of application, since it afects a
wide spectrum of domains, for example, IT, transport, and banks. It aims to standardize the accessibility
features and user interfaces [
        <xref ref-type="bibr" rid="ref4">4</xref>
        ].
      </p>
      <p>Continuous compliance is required by EU-based organizations, however, the environment that they
operate in, results in a challenging situation. Initially, derived from the complexity and the requirements
of the introduced laws, changes and adjustments to the organization’s capabilities are needed as a
response to the external legal context [11]. However, context factors of diferent origins, like political,
economic, social, technological, environmental, etc. (PESTLE analysis [12]), are always posing threats
to the compliance level of an organization to a specific act, even if they are introduced as opportunities
and threats rising from the organization’s context.</p>
      <sec id="sec-2-1">
        <title>2.2. Enterprise Modeling</title>
        <p>
          EM involves creating an integrated model of an organization that captures relevant aspects for a specific
modeling objective, such as concepts, goals, processes, or business rules. The integrated view of these
aspects is crucial for a holistic understanding of the organization [
          <xref ref-type="bibr" rid="ref6">6</xref>
          ]. Consequently, an enterprise model
is typically composed of various sub-models, each focusing on a particular aspect of the organization.
This modeling approach helps individuals within the organization gain a deeper under-standing of how
their work fits into the larger organizational framework and the role of supporting information systems
[13]. Common EM languages are the Unified Modeling Language (UML) [ 14] for domain, system, and
other modeling activities, and Business Process Model and Notation (BPMN) [15], for modeling of
organizational processes.
        </p>
        <p>Regarding EU act implementation, EM can facilitate a comprehensive understanding of how diferent
parts of the given organization interact, which is essential for aligning regulatory requirements with
organizational practices. An eficient EM framework can provide several specific benefits for the
task. First, it can enhance regulatory clarity by enabling a comprehensive and structured analysis
of the regulation’s content. This can help organizations interpret and apply regulations consistently,
reducing the risk of non-compliant practices. Second, it can support optimizing resource allocation by
documenting the specific areas where investments in technology, personnel, and processes are needed,
based on modeled gaps. Third, it promotes continuous learning and adaptation by incorporating
feedback mechanisms and structured model updates based on changes in regulations or organizational
contexts.</p>
      </sec>
    </sec>
    <sec id="sec-3">
      <title>3. Methodology</title>
      <p>The goal of this study is to elicit a set of requirements for a modeling framework that will support the
implementation of EU Acts in organizations. This can be considered as one of the initial steps of a DSR
[8] project. In particular, the DSR framework employed in this study is [16], which consists of five steps.
These are (i) Problem explication, (ii) Requirements definition and outline of the artifact, (iii) Artifact
design and development, (iv) Artifact demonstration, and (v) Artifact evaluation. This study comprises
partially the first, and essentially the second step of the project, being the one before the development
of the artifact. In other words, the aim of the project is the development of the artifact, yet, the aim
of this paper is the elicitation of the artifact’s requirements. A qualitative survey strategy has been
employed, combined with interviews as a data collection method and thematic analysis for analysing
the data.</p>
      <p>The overall research approach is based on the DSR principle that dictates identifying a category of
specific problems, abstracting into a generic problem, and providing a generic solution artifact that
can address all the specific problems that are specializations of the generic problem [ 16]. This study
concerns the implementation of two specific EU acts, which have been used as examples of specific
problems, the DORA, which is a regulation, and the EAA, which is a directive. The two diferent act
types are used to ensure that the generic problem can be addressed even when diverse specific problems
are used for the generalization. Thus, identifying requirements for implementing these two specific
acts enables a synthesis and abstraction that can provide an initial set of requirements for the generic
problem, which is the implementation of EU acts in organizations in general.</p>
      <sec id="sec-3-1">
        <title>3.1. Participants</title>
        <p>The selection of participants was performed using as criteria their professional background and expertise
with relevance for each act. In particular, the DORA participants were selected with a background in
security and finance, and the EAA participants were selected for their software development background,
and when applicable, accessibility expertise as well. All eleven participants are working in organizations
based in Sweden, and their work experience varies from three to thirty-eight years, with an average of
seventeen years of work experience per participant. The domains they come from vary, from economics
P1
P2
P3
P4
P5
P6
P7
P8
P9
P10
P11</p>
        <p>Senior Cyber Security Advisor
Cyber Security specialist
Information Security Specialist
Consultant
Manager/Cyber Security
Chief Information Security Oficer
Senior Software Engineer
Full-Stack Developer
Senior Web and Mobile Developer
Node Developer and Accessibility Specialist
Advisor on Accessibility/Accessibility Engineer</p>
        <p>Years of work experience
25
38
6
16
4
28
3
14
4
22
29
and law, to IT and Management. The common denominator in all cases is their experience or expertise
in the fields addressed by the two given acts. The initial contact with the participants was initiated via
Linkedin and personal contacts, followed by snowballing via recommendations by the initial participants.
Table 1 depicts the participants, with their assigned anonymous codes, their roles and domains, and
their years of work experience.</p>
      </sec>
      <sec id="sec-3-2">
        <title>3.2. Data Collection</title>
        <p>The collection of data was based on individual semi-structured interviews with the participants. Eleven
interviews were conducted in total, six of them focusing on requirements for implementing the DORA,
and the other five focusing on the EAA. Eight out of eleven interviews were held online for convenience
reasons, and the remaining three were conducted in person in the participants’ work environment. The
average interview time was one hour, and they were all digitally recorded.</p>
        <p>The data collection protocol consisted of questions about (i) the participants back-ground in relation
to the act (cyber-security or accessibility), (ii) their current involvement in implementation initiatives,
(iii) the essential facilitating factors for the given act, (iv) the essential hindering factors for the given
act, (v) how they perceive the overall attitude towards the act (personal and organizational), (vi) their
knowledge about the act, and potential dificulties to interpret it, (vii) the resources needed for the
implementation, both existing and needed, and how they can be acquired, (viii) existing technological
and/or operational frameworks, guidelines, tools and approaches used for the implementation, and (ix)
any training received, or planned to be developed/delivered about the implementation.</p>
      </sec>
      <sec id="sec-3-3">
        <title>3.3. Data Analysis</title>
        <p>Once the interviews were completed, the recordings were anonymized, transcribed and coded. The
collected dataset was subjected to descriptive coding, as described in [17]. The data analysis method
that has been employed is thematic analysis, which can be inductive or deductive [18]. Inductive is
driven by the data itself, minimizing the risk of researcher bias. Deductive thematic analysis concerns a
pre-existing research framework that drives not only the development of the data collection protocol,
but also the analysis procedure. In this study, inductive analysis has been employed, so, in practice, a
structured set of requirements has been formed based on the themes, categories and codes derived from
the collected empirical data. Both the coding and the analysis was completed in several iterations.</p>
      </sec>
      <sec id="sec-3-4">
        <title>3.4. Modeling</title>
        <p>
          The empirical results were summarized, combined, and abstraction was applied on them, in order to
produce a set of requirements for the generic problem. The result of these activities was a set of goals,
which are considered requirement artifacts, in the Requirements Engineering (RE) context [19]. A goal
is defined as a desired state of afairs that needs to be attained [
          <xref ref-type="bibr" rid="ref6">6</xref>
          ], and they are often decomposed into
sub-goals, forming a hierarchy of goals, which can be visualized as a model. In this study, the “For
Enterprise Modeling” (4EM) [
          <xref ref-type="bibr" rid="ref6">6</xref>
          ] approach has been employed for the development of a 4EM Goals model.
The 4EM Modeling Toolkit, developed in the University of Rostock, has been used for the practical
design of the model.
        </p>
      </sec>
      <sec id="sec-3-5">
        <title>3.5. Research quality</title>
        <p>This section will discuss the threats to the validity of this study, along with means employed to mitigate
them, whenever possible. Initially, the selection of the participants was performed following a purposive
and convenience sampling approach due to the limitations in time and resources. The experience with
the given acts, which was used a criterion, guaranteed that the interviews would provide value for
the research goal, however, more time and resources could potentially result in an optimal group of
participants, with a higher average in years of work experience. In order to minimize the individual
analyst’s bias, at least two of the authors were involved in every iteration of the descriptive coding and
thematic analysis. Finally, one point that needs to be mentioned is the limited generalizability of the
ifndings, because, at the current state of the project, there has been no evaluation or validation of the
requirements set.</p>
      </sec>
    </sec>
    <sec id="sec-4">
      <title>4. Empirical Results</title>
      <p>This section presents the empirical results of the survey, per act. Initially, the interviewees showed the
tendency to deviate significantly from the posed questions, which on one hand is expected during a
semi-structured interview, on the other hand, there were several topics and concepts brought up that
did not align directly with the posed questions. One overarching theme that was common in both parts
of the survey was the need to classify activities regarding the implementation and compliance to an act
in phases. This emerged organically, even if none of the posed questions explicitly mentioned specific
phases for act-specific implementations projects. Both the DORA and EAA respondents classified the
activities in three main phases, (i) the pre-implementation, (ii) the main implementation phase, (iii) and
the post-implementation phase. All the respondents are currently engaged in an implementation project
or planning for it, that is, they are in a preparatory state aligned with the identified pre-implementation
phase. To no surprise, there were minimum to no details elaborated about the post-implementation
phase, since the participants are lacking practical experience from that specific phase.
4.1. DORA
Initially, one of the main themes that emerged from the analysis of the DORA-specific interviews was
the need for regulatory clarity. The respondents discussed the need for clarification provided by the
authorities, mentioning specific institutions, like the Swedish Finansinspektionen (FI), from which
clarifications and guidelines are systematically expected.</p>
      <p>This also brought up the issue of misinterpretations during the absence of regulatory clarifications.
In practice, as the respondents pointed out, there are many factors that augment the diversity in
interpretations of an act. The most common factor that was mentioned was the interpretation per
country/member state of the EU. Another important factor that was mentioned was the interpretation
of what is a requirement in DORA and what is not, in other words, what must be implemented and what
should/could/may be implemented. From a RE perspective, this can be perceived as lack of clarity in
prioritization [19], leading to diversity in interpretations. This is also relevant to another factor leading
to interpretation, which was mentioned as the degree of implementation, meaning that it is not clear
when the efort has reached adequate levels and compliance has been reached. This is associated to the
lack of clear compliance criteria, which were mentioned as an omission derived from the lack of clear
guidelines, both about the implementation, and about its assessment. Finally, this theme also includes
the updates on existing regulations.</p>
      <p>One of the most important aspects that emerged as a theme was the existence, documentation and
analysis of the relevant knowledge about DORA. The participants brought up knowledge about similar
earlier legislation about the same domain, like the Directive on security of Network and Information
Systems (NIS) and NIS2 [20].</p>
      <p>Another important type of relevant knowledge concerns the contextual factors that are essential for
the implementation. The theme that emerged was context-dependency for the implementation. Three
important factors were mentioned. The size of the organization was the first one, with the participants
mentioning that bigger organizations are overall better prepared for implementing DORA, since there
are parts of DORA that are already fulfilled, while, on the contrary, smaller organizations have never met
such demands. Another factor is the business domain, with organizations like banks being considered
more prepared in comparison with organizations like insurance companies. One last factor that was
mentioned was the risk-level, with organizations with higher risk-level, like banks, being considered
harder to implement that low-risk ones.</p>
      <p>Another theme that emerged was the existence of existing methods and tools that are deemed
necessary during the DORA implementation. One such method that was strongly emphasized was
gap analysis, which was mentioned as being essential both during the pre-implementation and
postimplementation. The mention about pre-implementation derived from practical experience, while gap
analysis in post-implementation was only mentioned theoretically and on a planning level. Another
strongly emphasized method was risk management and analysis. A lot of details were emphasized about
properly establishing risk management, so that proper risk assessments are conducted and reporting
systems are set up. Best practices are also part of the knowledge that is required for the implementation,
coming from either diferent member countries or earlier implementations of similar acts. This also
involves variations and best practices from third parties in the organization’s ecosystem, for which
compliance also needs to be monitored.</p>
      <p>Finally, another theme concerned the required training, which concerns how this identified knowledge
needs to be transferred. The means that were mentioned were workshops, seminars, and lectures.
4.2. EAA
The EAA part of the survey resulted in a set of themes with several overlapping parts with the DORA
one. Initially the first important theme concerned management enablement. The participants have
emphasized the importance of supporting the management, especially when it comes to organizational
support. There were also specific activities that were deemed as essential and were categories in the
results of the thematic analysis. The first one was the allocation of resources. This includes both material
and immaterial resources, for example, financial resources, infrastructure, and equipment. Knowledge
and human resources have also been mentioned, however, they were emphasized enough for them to
be independent themes, which will be discussed later in this section. Budgeting activities have also
been mentioned and belong here. They are considered important by the interviewees, since they can
eficiently support the proper allocation of resources. The final activity for which the managers of
an organization will need support, is the establishment of dedicated personnel for the implementation
project. The EAA participants emphasized more on the aspect of dedicated personnel, also combining it
with the education aspect that is discussed in the next paragraph. More specifically, dedicated personnel
can be acquired both by supporting the management in hiring individuals with the required expertise
and knowledge, and by training the existing staf in the required knowledge.</p>
      <p>The required knowledge and education themes are overlapping with the DORA findings to a significant
degree. Education is also deemed valuable in the EAA implementation and can be delivered via seminars
and workshops. The required knowledge on which the individuals have to be educated concerns,
legislation training, both current and similar relevant guidelines like the Web Content Accessibility
Guidelines (WCAG) [21], technical training and accessibility training, which is act-specific knowledge.
The participants also emphasized on the need to have education that also promotes a shift in the mindset
of the organization towards a company-wide mindset of the EAA. Finally, in a similar way to DORA,
EAA implementation can benefit from familiarity with best practices. What was emphasized for EAA
but not in DORA was the need to communicate best practices, even among teams that implement the
EAA in parallel.</p>
      <p>Another important theme that emerged from the EAA part was the stakeholder engagement. The
improvement of the relations with stakeholders and their inclusion was deemed essential. The
participants emphasized the need not only to establish feedback mechanisms, like discussion and thought
panels, but also the integration of the collected feedback, which can enhance the implementation. The
additional benefits from stakeholder engagement, according to the interviewees, are the promotion
of the EAA’s importance, and potentially, new perspectives and ideas that may rise from the efective
interaction with the stakeholders.</p>
      <p>Technological and operational adjustments is a theme that included a variety of concepts about the
EAA implementation. Initially, there are specialized tools that can be employed and integrated with
the implementation process. Categories of such tools that has been mentioned by the participants are
scaling tools, compliance monitoring tools, auditing tools, and tools that individuals with disabilities
use commonly, and accessibility checklists. These are deemed as highly important because software
development involves a high degree of automation, and the tools can improve the eficiency of the
implementation. Naturally, this also requires keeping the existing IT infrastructure that exists in the
organization and is relevant with the implementation of the EAA, up to date. In a similar way, the
processes of the organization will potentially have to be adjusted, either by adopting new ones, for
example via best practices, or by performing changes to the existing ones.</p>
    </sec>
    <sec id="sec-5">
      <title>5. The Requirement Set</title>
      <p>Based on the findings derived from the the survey, a synthesis and abstraction have been performed. In
particular, all the knowledge required for an implementation has been summarized into one goal, which
includes previous legislation, contextual factors, best practices, technical and act-specific knowledge.
Other parts were elaborated more than the theme level, for example the ways for expert staf acquisition
and the stakeholder engagement, where more detailed sub-goals were introduced, like the training and
hiring of expert staf, and the implementation of feedback mechanisms and integration of the collected
feedback, respectively. The purpose of these activities was to reflect more on the operational capabilities
of the envisioned artifact.</p>
      <p>Tables 2-4 present the goals for the pre-implementation, implementation and post-implementation
phases, along with their descriptions, and the survey part that they originated from.</p>
      <sec id="sec-5-1">
        <title>5.1. The 4EM Goals model</title>
        <p>Based on the list of goals that was elicited from abstracting and synthesizing the empirical results of
the two-part survey, a 4EM Goals model (Fig. 1) has been developed to complement the inter-goal
relationships, for example, goals and sub-goals the existence of which supports or hinders other goals
and sub-goals.</p>
      </sec>
    </sec>
    <sec id="sec-6">
      <title>6. Discussion</title>
      <p>Initially, the elicitation of requirements and initial outline of artifacts is iterative, like any other DSR
step. This study has completed the first iteration, which provides a solid basis for further elaboration,
and also outlines the essential capabilities of the artifact under development.</p>
      <p>To prepare for the implemen- Before the implementation, a series of preparatory
activitation ties should be supported by the artifact.</p>
      <p>To provide organizational
support</p>
      <p>Organizational support should be facilitated by the artifact,
in terms of managerial activities.</p>
      <p>To enable management for
implementation activities</p>
      <p>Management should be given the proper level of support
by the artifact before the implementation.</p>
      <p>To establish dedicated per- The implementation requires personnel dedicated to it, and
sonnel the artifact should support establishing it.</p>
      <p>To manage the allocation of
necessary resources</p>
      <p>Resources of all kinds are needed for the implementation
and the artifact should support their allocation.</p>
      <p>To perform budgeting activi- Budgeting activities will be supported, since they can be
ties used for optimizing resource allocation.</p>
      <p>To acquire staf with the
required expertise
To train existing staf</p>
      <p>The artifact will support the acquisition of expert staf.</p>
      <p>Staf training will be supported.
10 To develop training
programs</p>
      <p>Developing lectures, seminars, and simi-lar training
activities should be supported by the artifact.
11 To hire expert staf</p>
      <p>The artifact should support employing experts.
12 To identify required knowl- Act-specific knowledge, like previous regulations, needs to
edge be identified and trained to employees.
31 To perform gap analysis</p>
      <p>A gap analysis component should be included.</p>
      <p>One potential limitation of this study is the restricted areas of the experts. The financial and
cybersecurity domain, and software development domain, are eficient for the exploration of DORA and EAA,
respectively. However, the introduced generalization that has been performed in this study may benefit
significantly from the inclusion of experts from diferent areas. Optimally, the included experts’ areas
should be as diverse as the topics addressed by EU acts.</p>
      <p>The current version of the requirements set, split into phases and with several linear and succeeding
activities indicate the need for developing a method artifact to be used as the envisioned modeling
framework. A modeling method includes additional components [22], that is, semantics, syntax,
procedure, mechanisms, and potentially a notation. These will require additional technical requirements.
Technical requirements for a modeling framework are important, yet, they have not been addressed in
this study. This was a deliberate omission, since we opted for reporting on the frame-work’s envisioned
capabilities, and not on its form. We consider this an early stage of the project for eliciting technical
requirements for the tool. Naturally, every DSR project has an iterative nature, and the elicited set
of requirements is expected to evolve over the forthcoming iterations, and also be complemented by
technical modeling requirements.</p>
      <p>The current version also involves several external components, for example gap analysis, which has
been emphasized as essential both in the pre- and post-implementation phases, risk management and
analysis approaches, auditing and budgeting techniques, existing tools, even educational formats like
workshops and seminars, or educational content like best practices and earlier legislation. On the one
13 To support the implementa- The artifact must facilitate the implementation activities
tion during the main phase.
14 To ensure regulatory clarity</p>
      <p>Ambiguous parts of an act must be addressed.
15 To use detailed guidelines</p>
      <p>The artifact should facilitate the use of implantation
guidelines for the given act.
16 To update regulations
regularly</p>
      <p>Regulations are often revised and their updates must be
addressed by the developed artifact.
17 To clarify updates</p>
      <p>Ambiguous updates of an act must be addressed.
18 To implement technologi- An act may require adjusting the technological and opera- EAA
cal and operational adjust- tional infrastructure, tools and/or processes.</p>
      <p>ments
19 To employ specialized tools</p>
      <p>The integration of specialized tools must be addressed by
the developed artifact.</p>
      <p>EAA
20 To keep ICT infrastructure
updated</p>
      <p>The organization’s technological infrastructure may re- EAA
quire updates that need to be facilitated.
21 To establish risk
management procedures</p>
      <p>Risk management approaches should be included as
artifact component(s).
22 To set up reporting systems</p>
      <p>Risk reports have value that the artifact cannot overlook,
so, proper systems need to be set up.
23 To conduct risk assessments</p>
      <p>The actual assessments should also be facilitated.
24 To monitor and evaluate
compliance</p>
      <p>The implementation will need to be dynamically monitored
per steps and activities.
25 To perform audits</p>
      <p>The artifact should include audit component(s).
26 To engage stakeholders ef- The efective interaction with the acts’s stakeholders must
fectively be facilitated by the artifact.
27 To monitor third-party rela- Third parties and their compliance to the act needs to be
tionships monitored by the supported organization.
28 To integrate stakeholder
feedback</p>
      <p>The integration of the feedback collected by the stakehold- EAA
ers must be systematically integrated.
29 To implement feedback
mechanisms</p>
      <p>There must be systematic mechanisms to collect feedback
from stakeholders.</p>
      <p>EAA
hand, this has practical value from both operational and design perspectives, since it saves resources by
avoiding the need to “reinvent the wheel”. On the other hand, this is a strong indication that complex
integration eforts will be required to ensure the compatibility of all the external components, both
methodologically and data-wise.</p>
      <p>Strong emphasis has been put on training in specialized knowledge, a fact indicating that the
developed artifact will need to properly document and classify all types of relevant knowledge, that is,
contextual, legislative, both in terms of current and previous legislation, technical, operational and any
other act-specific knowledge. From a design perspective, the artifact must point to the relevant and
valuable context information and knowledge, while in parallel optimizing the process by avoiding to
waste time and efort on anything that bears no value for the implementation.
To support EU act implemen- The main goal of the artifact will be to support implement- DORA,
tation during all its phases ing EU acts in organizations. EAA
30 To assess the impact of the
implementation</p>
      <p>When the implementation is complete, the artifact must
provide means to assess its impact.</p>
      <p>A gap analysis component should be included.</p>
      <p>The fact that there were no actual data collected about the post-implementation phase indicates
two possible paths to fill this gap. There can either be a succeeding iteration with experts that have
completed the implementation of an older act and have experienced analyzing the impact of such a
project, or repeat the data collection activities for the given acts once the project has already been
completed and the post-implementation phase has been initiated. This is one of the potential paths
for future research derived from this study, and we aspire that the community will be motivated to
contribute with valuable insights.</p>
      <p>Another potential path for future research would be to complement this study with additional
requirements from implementation projects that concern diferent acts, as for example the recent AI act
[10]. On an alternative research plan, the elicited set of requirements could lead to the development
of an initial version of the envisioned artifact, which could, in return, be tested and evaluated on the
implementation of the AI act.</p>
      <p>One final path for future research would be to combine the requirement set or the artifact that
will be developed based on it, with existing EM approaches that are specialized for modeling change
phenomena and evaluate their eficiency in modeling an EU act implementation. One potential candidate
is the KYKLOS method [23] and tool [24], which is an EM method specialized for modeling changing
organizational capabilities. Adopting the perspective that every EU act implementation is a transition
of an organization’s capability, from a non-compliant version to the compliant version of the capability,
enables potentials for additional paths in research around EM and EU act compliance.</p>
    </sec>
    <sec id="sec-7">
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requirements towards the development of a framework based on Enterprise Modeling. A two-part qualitative
survey has been conducted to collect data from expert interviews regarding two specific EU acts, the
DORA and the EAA. The results have been synthesized into one unified set of goals. Supporting
management for expert staf acquisition and optimized resource allocation, regulatory clarity, risk
analysis, efective stakeholder engagement, and technological and operational adjustments are several
of the main identified aspects that a domain-specific modeling framework should address.
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