EBF response to EBA draft recommendations on outsourcing to cloud service providers

EBF advisor: Noemi Papp

Publication date: 19 August 2017
In the official response the following was highlighted:

• EBF supports the additional guidance to the existing CEBS Guidelines.

• However, the draft recommendations remain too high-level and could leave room to multiple interpretations at national level. 


• We are additionally concerned that the draft EBA recommendations, as they currently stand, may not be sufficient to have a positive impact on cloud adoption within financial services in Europe.

• EBA's objective should be to reach a point where notification on a case-by-case basis is not required at either EU or national level.

• It is important to continuously assess and update the EU outsourcing regulation to ensure it is adapted to the technology-enabled world.

• Cloud Service Providers should be certified based on recognised international standards.

• The development of high-level principles by the industry should be favoured.

• Further consideration should be given to the GDPR to be implemented by May 2018.

• The EBA recommendations should explicitly mention the underlying risk driver.

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