Digital Finance: amending Directive regarding Digital Operational Resilience requirements

The EMA is the EU trade body of FinTech and BigTech firms engaging in the provision of alternative payment services and the issuance of electronic money. Our members include leading payments and e-commerce businesses providing online/mobile payments, card-based products, electronic vouchers, virtual currency exchanges, electronic marketplaces, merchant acquiring services and a range of other innovative payment…

Dear Sir or Madam, Please find attached the Position Paper of the Association of Foreign Banks in Germany dated 18 May 2021 with respect to the proposal for a Regulation on digital operational resilience for the financial sector (DORA).

Intesa Sanpaolo welcomes the opportunity to provide its preliminary comments to the European Commission’s proposal for a Regulation on Digital Operational Resilience for the financial sector (so-called DORA). Intesa Sanpaolo supports the aim of this proposal which is to set up a detailed and comprehensive framework on digital operational resilience for EU financial entities.

BME Position Paper on European Commission’s proposal for a Digital Operational Resilience Act (DORA) BME welcomes and fully supports the work of European regulators aimed at making Europe fit for the digital age and developing a harmonised regulatory regime.

BVI fully supports this important initiative. The entire financial market will be significantly influenced by the increased availability of data, algorithms, the digitalisation of assets, new processes in custody and settlement, and reporting.

We agree with the general findings and the 4 main risks identified. The desire for “resilience” seems perfectly coherent. However, we are very concerned that the new constraints could be very complicated to apply for small businesses, which represent the vast majority of stakeholders.

The German insurance sector supports the goal of strengthening the resilience of ICT systems used in the financial sector against risks and dangers. However, this should neither lead to parallel regulatory sys-tems nor to considerable impediments. Insurers are already subject to extensive regulatory requirements such as Solvency II and Delegated Regulation (EU) 2015/35, which include ICT applications.

LSEG welcomes the opportunity to comment on the European Commission’s legislative proposal on Digital Operational Resilience (DORA). Key highlights: - LSEG supports the harmonisation of requirements related to operational resilience, especially when it comes to outsourcing to “Critical ICT Third Party service Providers (CTPPs)”.

The European Banking Federation (EBF) welcomes the opportunity to share views on the Commission’s proposal of a Regulation on Digital Operational Resilience for the financial sector (DORA). Based on the EBF key messages on DORA, the following positions and suggestions of amendments reflect the current understanding of European banks.

The Association for Financial Markets in Europe (AFME) supports the European Commission’s proposal for a ‘Regulation on Digital Operational Resilience in the Financial Sector’ (DORA). To support the Commission's proposal we have summarised our key considerations: - A risk-based approach should be adopted that aligns with the existing EBA Guidelines on ICT and Security Risk Management and Guidelines on Outsourcing…

RELX welcomes the opportunity to provide feedback on the European Commission’s proposal for a Digital Operational Resilience Act (DORA). RELX is a global provider of information-based analytics and decision tools for professional and business customers across a range of sectors, including financial services, science, technology, medical, healthcare and energy.

As the financial services industry continues to evolve and digitalize, Microsoft fully supports and acknowledges the timely efforts of the European Commission to strengthen the operational resilience of the European financial system, while building on the existing guidance of the European Supervisory Authorities.

The EMA is the EU trade body of FinTech and BigTech firms engaging in the provision of alternative payment services and the issuance of electronic money. Our members include leading payments and e-commerce businesses providing online/mobile payments, card-based products, electronic vouchers, virtual currency exchanges, electronic marketplaces, merchant acquiring services and a range of other innovative payment…

Established nearly 40 years ago, France Invest represents most venture capital and private equity teams based in France. The Association also welcomes French infrastructure and private debt teams, as well as service providers and financial institutions based in France which support and advise investors and entrepreneurs in the structuring and management of their partnerships.

Dear Sir or Madam, We support the Commission’s plans regarding to put in place regulation addressing digital operational resilience on a union-wide and uniform manner, especially to reach a more coherent level of ICT risk policy in comparison to today’s minimum harmonisation directives or principled-based regulations.

The draft DORA regulation is an opportunity to further accelerate the digital transformation of finance and show the EU’s global leadership in defining a first-of-its-kind framework for outsourced ICT operations in financial services. Yet, unclear and potentially overlapping provisions in the existing draft risk to dramatically hamper the achievement of these goals.

The European Association of CCP Clearing Houses (EACH) represents the interests of Central Counterparties (CCPs) in Europe since 1992. CCPs are financial market infrastructures that significantly contribute to safer, more efficient and transparent global financial markets. EACH currently has 19 Members from 15 different European countries.

DORA is a step towards harmonisation, which the industry sorely needs. The implementation of EU-wide security standards and harmonised tests and uniform reporting structures is crucial if we are to deepen harmonisation of the single European digital market. Removing national inconsistencies in implementing security standards and in supervisory practices will be key to fostering EU-wide innovation.

As cybersecurity rating agency, our comments are focused on the 'Oversight framework of critical ICT third-party service providers' (Section II - Chapter V). Based on our 10 years of experience in third-party risk management the proposed approach faces many challenges: - Increases audit fatigue - Would impact on the ICT services market (not neutral) - Modify the operational activities of ESAs - Raise potential…

Thank you for the opportunity to comment on the European Commission’s Digital Finance Package. The DGRV — Deutscher Genossenschaftsund Raiffeisenverband e.V. currently brings together 5.330 cooperatives with 19,8 million members.

Filed in German · English published by the European Commission

Thank you for the opportunity to comment on the European Commission’s Digital Finance Package. The DGRV — Deutscher Genossenschaftsund Raiffeisenverband e.V. currently brings together 5.330 cooperatives with 19,8 million members.

Filed in German · English published by the European Commission

The European Data Centre Association (EUDCA) represents the European data centre operator community in its dealings with the European Union as well as National governments. The European Commission is to be commended for focusing on the residual and growing challenges associated with the “Digital Operational Resilience for the Financial Sectors.” As the Inception Impact Assessment states in its opening, “The…

The technical and communication options currently in place allow for the creation of an environment of safe access to the banking services also to persons with limited mobility or orientation. However, some solutions currently used do not allow for such access and information needed by a person with a disability.

Filed in Slovak · English published by the European Commission