DORA – the Subcontracting RTS is now finalised, what do you need to know?

The European Commission has now finalised the long-awaited Subcontracting Regulatory Technical Standards (RTS), with the intention of providing clarity to financial entities and ICT providers on DORA’s requirements for subcontracting ICT services which support critical or important functions.

The Subcontracting RTS was rejected by the Commission and subject to some last minute changes which reduced its scope (which was welcomed by financial entities and suppliers). The changes are narrower than they first appear. There still remain a lot of detailed requirements that apply in relation to subcontracting arrangements, including mandatory flow downs of provisions on audit, monitoring, business continuity, and security that go beyond existing regulations.

Join us for this Q&A session during which our DORA leads will:

• recap on how DORA applies in relation to subcontracting arrangements;
• consider the changes made to the final draft of the Subcontracting RTS; and
• summarise what this means for financial entities and suppliers.