Implementation of the Digital Operational Resilience Act
Position Paper
7 May 2023
Digital, Financial services

The three European Supervisory Authorities (ESAs) are currently tackling the operational aspects of the Digital Operational Resilience Act (DORA). In this context, businesses from both the financial services and digital sector have identified areas of the legislation on which clarity is particularly needed. In order to ensure legal certainty and allow industry to properly prepare for the new rules, the ESAs should aim to further clarify the following:

• Level of aggregation within a Group to which DORA would apply.
• Criteria and process around designating critical information and communications technology (ICT) third-party providers.
• Procedures that apply to incident reporting.
• Consistency with other EU legislation.

Related items

Position Paper
10 Nov 2026

Making web scraping rules work for AI

The European Data Protection Board’s draft guidelines on web scraping for generative AI are an opportunity to provide greater legal certainty and support Europe’s AI competitiveness. However, some proposed requirements risk creating disproportionate burdens for AI developers.

A pragmatic, risk-based approach is needed to ensure the rules reflect the technical realities of AI development. This includes proportionate transparency obligations, recognition of the need for diverse training datasets and greater alignment with the AI Act and Digital Omnibus. Clear, harmonised rules are essential to protect personal data while enabling innovation.

Read our consultation response to learn more about the recommendations.

Digital
Read more
Read more about Making web scraping rules work for AI
News
6 Nov 2026

Digital Economy Conference 2026: in review

AmCham EU’s 13th Annual Transatlantic Digital Economy Conference took place on Thursday, 5 November, under the theme Cutting through complexity. The event brought together policymakers, regulators and industry leaders to discuss how clear, workable frameworks and closer EU-US cooperation can bring more coherence to the digital landscape and support economic growth.

Digital
Events
Read more
Read more about Digital Economy Conference 2026: in review
Position Paper
26 Oct 2026

Digital euro: getting the final design right

Financial services
Read more
Read more about Digital euro: getting the final design right