EBA · 2025_7538 Rejected question

Credit institutions should not consider as outsourcing

Regulation
Directive 2013/36/EU (CRD)
Article
74, para. 3
Topic
Other issues
Submitted by
Credit institution
Submitted
2025-07-30
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Question

Within Title II, Section 3, Recital 28 Guidelines on outsourcing an exemption what should not be considered an outsourcing is given. Under this exemption can we consider that purchases of goods e.g., standard software or hardware without customization or integration into critical processes, are not outsourcing? For example if the SaaS application is used solely for non-critical, non-banking functions  (e.g., HR training platforms, marketing tools), and does not impact the institution’s operational resilience or critical functions, can it be treated from a bank perspective as purchase of goods that  fall outside the EBA guidelines on outsourcing arrangements scope?

Background

Title II, Section 3, Recital 28
No answer published yet.

Original source: European Banking Authority, Q&A ID 2025_7538

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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