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.
This is a very dangerous take - while at this point in time the RTS have not yet been formally adopted by all the relevant bodies, they will be, at which point they will be enforceable.
I work in banking. This was the take of a lawyer from my local (national) enforcement body in denmark (finanstilsynet). They can't make direct recommendations, because the specific judgement about what is delegated to each RTS is itself delegated to EU courts.
That didn't stop them from giving me their opinion which was that certain parts of certain RTS's fell well outside the delegated responsibility, and would therefore never be enforcable. No matter if it was adopted, because the RTS was never delegated the power to define what it decided to define.
This doesn't mean that you should ignore the RTS, but you need to remember what is law and what isn't. RTS's are never enforcable, they are only technical definitions which you use to enforce that actual law.
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.