The final report on the Regulatory Technical Standard (RTS) on Subcontracting introduces helpful guidance and addresses several key points raised by industry during the consultation period. However, certain provisions remain concerning. The scope of application continues to be overly broad, imposing all the requirements in the RTS on all information and communication technology (ICT) subcontractors that provide ICT services supporting critical or important functions, which risks unnecessary complexity. A more focused application of the requirements to subcontractors that effectively underpin the primary ICT service would allow for a more proportionate and risk-based approach to third-party risk management. Furthermore, the timeline for implementation is insufficient given the scale of changes required. The RTS introduces substantial new obligations that will necessitate updates to existing contractual and operational frameworks. To ensure smooth and effective compliance, a minimum implementation period of two years from the finalisation of the RTS is essential.
Recommendations for Regulatory Technical Standards on Subcontracting under the Digital Operational Resilience Act
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Whilst not the panacea to all of Europe’s funding challenges, learn why revitalising securitisation in Europe will help unlock private finance and thereby create better conditions for the financing of the EU economy.
Consultation response: Digital Fairness
Consultation response: Consumer Agenda 2025-2030
AmCham EU's consultation response in relation to the Consumer Agenda 2025-2030 calls on the Commission to streamline and harmonise consumer rules, accelerate digital product information, and provide clear EU-level guidance. Stronger action is also needed to protect consumers from counterfeit and unsafe goods while ensuring rules remain fair, future-proof and innovation-friendly.
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