EBA · 2025_7421 Rejected question

Definition and Scope of DORA

Regulation
Regulation (EU) No 2022/2554 (DORA Reg)
Article
3, para. 1
Topic
ICT third-party risk management
Submitted by
Consultancy firm
Submitted
2025-04-22

Question

Does the definition of 3.19 include all service providers - no matter the relevance of their service for the digital resilience of the financial service e.g. providers of an employee survey tool or a recruitment tool, where the absence of their services would no have no impact on the resilience security of network and information systems supporting the business processes of financial entities. If in the affirmative, does this mean that any ICT third-party service provider falls within the scope of DORA ( see Article 2.1(u). As a consequence a service a digital employee exercise app provider will fall within the scope of DORA if they sell their services to a financial service provider? If in the affirmative, is this proportionate with regard to the impact that this has on ICT third-party service providers whose services have no impact on the security of network and information systems supporting the business processes of financial entities. If in the affirmative, do the financial authorities now have competence over all ICT third-party service providers, regardless of what kind of services they provide as long as they are providing services to a financial entity?  * financial entity = or any other entity besides an ICT service provider

Background

The background of this question is that banks and other financial institutions are requesting, with reference to DORA, that ICT service providers who have no impact on the security of network and information systems supporting the business processes of financial entities, to amend contracts.
No answer published yet.

Original source: European Banking Authority, Q&A ID 2025_7421

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.

Similar Q&As

More Q&As on this topic

📋 Track EU financial regulation continuously

Forseti monitors EU financial regulation and delivers personalised alerts anchored to verified official sources.

14-day free trial. No credit card required.