DORA Guide Outlines Cloud Third-Party Risk Duties for Financial Institutions

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Financial firms increasingly run applications, databases, and transaction systems on cloud platforms, creating layered technology dependencies that can spread a single failure across services. The Digital Operational Resilience Act, applicable since 17 January 2025, requires these entities to manage ICT third-party risk within their broader risk framework under Article 28. Regulatory responsibility stays with the financial entity even when a provider runs the infrastructure. The guide recommends mapping dependencies and assessing business impact, sensitivity, and substitutability to decide how much monitoring and contractual protection each service needs. It also highlights the Register of Information and Article 30 contract requirements, such as audit rights, subcontracting terms, and exit provisions.

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