EIOPA · DORA 248 - 3376
Other DORA topics
- Regulation
- (EU) 2022/2554 - Digital Operational Resilience Act (DORA)
- Article
- 3
- Topic
- Other DORA topics
- Submitted
- 2025-07-03
- Answered
- 2025-11-21
Question
With regard to ancillary insurance intermediaries, should the thresholds for determining whether an entity is a micro, small or medium-sized enterprise, as set out in Article 3(60), (63) and (64), be based on the turnover generated exclusively by insurance activities or on the entity's total turnover?
Background
These obligations were primarily designed for financial entities, and the inclusion of revenue from non-financial activities appears inconsistent with the spirit of the Regulation. Moreover, since ancillary insurance intermediaries that are exempted are not subject to DORA (see Q&A - 3074 - DORA096), this could create a competitive imbalance and incentivize regulatory arbitrage between exempted and non-exempted AIIs."
Answer
This question has been rejected because the matter falls within the scope of Q&A 099 and Q&A 237 respectively.
This Q&A is published by European Insurance and Occupational Pensions Authority and is non-binding. It does not constitute legal advice. Updated weekly from official ESA sources.
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