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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Banking Competitiveness Report: Single Market integration and openness must drive reform
The European Commission’s Banking Competitiveness Report comes at a critical moment for Europe’s investment agenda. Closing Europe’s investment gap requires a banking sector able to mobilise capital at the scale the Savings and Investments Union demands. This is dependent on a Single Market that is not only competitive and integrated but open for all banks operating in the EU to act as facilitators of investment. The report provides a window of opportunity to anchor that openness at the centre of the competitiveness agenda.
The report correctly identifies a set of barriers holding back Europe’s banking competitiveness, both in the regulatory framework and in the way that framework is supervised. Undue complexity and divergent national implementation continue to raise the cost of financing for European households and businesses, underlining the need for an ambitious banking omnibus that simplifies rules and delivers greater consistency across the EU. At the same time, the report is right to call for a more proportionate, risk-focused supervisory culture that examines whether burdensome practices are weakening the attractiveness of Europe’s banking ecosystem. A new banking competitiveness agenda should build on both priorities: simpler, more coherent rules and supervision that enables internationally active banks to support investment.
Internationally active banks, including third-country groups with a substantial European footprint, are central to delivering this agenda. These institutions channel global capital to European companies, underpin the liquidity and depth of EU capital markets and help international investors finance opportunities in Europe. Europe remains a strategic market for these firms, and their investment demonstrates confidence in European growth, European companies and European opportunity.
The test of genuine integration is whether a banking group can serve customers across the Single Market without rebuilding its operations in each Member State. The report recognises that divergent national application of EU rules discourages banks from offering pan-European services and consequently results in costly duplication and regulatory burden across jurisdictions. A more competitive framework would enable European and international institutions to thrive in Europe, offering clients choice and a full suite of payment and banking services across the Single Market.
Coherent implementation will determine whether these reforms enhance competitiveness. Where the framework adapts international standards to EU specificities, the test should be whether the result preserves a level playing field for banks competing in global markets and remains consistent with the standards those banks apply across jurisdictions.
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Sustainable Finance Disclosure Regulation 2.0: getting the architecture right
The EU’s sustainable finance rules should help investors understand where their money is going and support Europe’s transition. The Commission’s proposal improves the current system, but some changes are still needed.
The new Transition category should focus on whether companies are cutting emissions, not on the sector they operate in. The 70% threshold should stay. The rules should also work with MiFID II and the EU Taxonomy.
Companies need 24 months to prepare. Firms that fall outside the new scope should stop reporting as soon as the rules enter into force.
Read the paper to learn how SFDR 2.0 can direct more capital towards Europe’s transition.
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Branching out with AI
Meta’s open-source Canopy Height Maps helped the European Commission’s Joint Research Centre improve its 2020 Global Forest Cover map, demonstrating how artificial intelligence can strengthen Europe’s ability to monitor forests and advance climate and biodiversity goals. Developed with the World Resources Institute, the maps use Meta’s DINO self-supervised computer vision model to estimate tree height from satellite imagery. This helped researchers apply the five-metre threshold used in many international forest definitions and better distinguish forests from other tree-covered land, including agricultural tree crops. The resulting product, available through the EU Forest Observatory, provides one of the most comprehensive open views of global forest cover. Read more on Invested in Europe.
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