EBA · 2025_7367 Rejected question

Correct classification of services related to the 'reselling' of software provided in SaaS mode

Name: Correct classification of services related to the 'reselling' of software provided in SaaS mode: EBA Q&A — EU Financial Regulatory Q&A
Creator: European Banking Authority
License: https://creativecommons.org/licenses/by/4.0/

Regulation: Regulation (EU) No 2022/2554 (DORA Reg)
Article: Regulation (EU) 2024/2956 - ANNEX III
Topic: Register of information (DORA)
Submitted by: Individual
Submitted: 2025-03-05

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Question

With reference to the correct identification of the type of ICT services, taking into account the types contained in ANNEX III of Regulation (EU) 2024/2956, how should services related to the 'reselling' of software provided in SaaS mode be classified?

Background

The doubt arises from the fact that access to software provided in SaaS mode (e.g., Microsoft 365) often occurs through a reseller and not with direct access to the owner of the software and the underlying infrastructure. The identifier S13 obviously excludes this mode of software delivery, and therefore the only alternative remains the identifier S19. However, the latter seems to refer to SaaS services provided directly by the owner.

No answer published yet.

Original source: European Banking Authority, Q&A ID 2025_7367

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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