EBA · 2024_6998 Rejected question

Direct and indirect applicability of DORA

Regulation
Directive 2022/2556/EU (DORA Dir)
Article
2
Topic
Other DORA topics
Submitted by
Industry association
Submitted
2024-02-06

Question

Should a credit bureau apply DORA directly, similar to any other financial entity, as an Account Information Service Provider or AISP, or should the CRA apply DORA indirectly, as an ICT third-party provider?

Background

It is not uncommon for credit bureaus to possess a license allowing them to offer Account Information Services (AISP) under Article 33(1) of Directive (EU) 2015/2366. If it is assumed (see a previous question from ACCIS) that the services provided by credit bureaus typically fall within the category of ICT services under DORA, there may be an instance of dual application of DORA, both as AISP (article 2.1.c) and ICT Services Provider (article 2.1.u)
No answer published yet.

Original source: European Banking Authority, Q&A ID 2024_6998

This Q&A is published by European Banking Authority and is non-binding. It does not constitute legal advice. Updated weekly from official ESA sources.

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