EIOPA · DORA 256 - 3398

Other DORA topics

Regulation
(EU) 2022/2554 - Digital Operational Resilience Act (DORA)
Article
3
Topic
Other DORA topics
Submitted
2025-07-29
Answered
2025-11-21

Question

Based on the definition of DORA Article 3(21) and DORA030 - 2999, how can the answer regarding the classification of ancillary services as financial services be interpreted in accordance with DORA and in the case of contractual triangular relationships?

Background

The above-mentioned reply stated: "The same rationale applies to ancillary services provided by an entity, depending on whether such ancillary services are regulated financial services or a service inseparable from, indivisible from, preparatory or necessary for the provision of a regulated financial service, and are not provided in a standalone manner." This allows for interpretations based on the following questions: What role does it play in classifying a service as a regulated financial service if the contracting party and the provider of the service are different? What role does it play if either only the contracting party or the provider is a regulated financial undertaking, or if IT infrastructure (already covered by a DORA agreement) by another ICT provider is used for a service?

Answer

This question has been rejected because it is unclear.

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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