Recital 2
Digital Operational Resilience Act · UE 2022/2554
| (2) | The use of ICT has in the past decades gained a pivotal role in the provision of financial services, to the point where it has now acquired a critical importance in the operation of typical daily functions of all financial entities. Digitalisation now covers, for instance, payments, which have increasingly moved from cash and paper-based methods to the use of digital solutions, as well as securities clearing and settlement, electronic and algorithmic trading, lending and funding operations, peer-to-peer finance, credit rating, claim management and back-office operations. The insurance sector has also been transformed by the use of ICT, from the emergence of insurance intermediaries offering their services online operating with InsurTech, to digital insurance underwriting. Finance has not only become largely digital throughout the whole sector, but digitalisation has also deepened interconnections and dependencies within the financial sector and with third-party infrastructure and service providers. |
In Luxembourg, the CSSF published in 2024 a DORA implementation circular (CSSF circular 24/847 on ICT incident notification) which continues the approach of CSSF circular 22/806 on ICT outsourcing governance. This continuity means that the mapping of digitalised functions expected under DORA must be consistent with the outsourcing register already required by 22/806: any function listed in Recital 2 (payments, post-trading, underwriting, InsurTech) missing from the 22/806 register becomes an immediate red flag during a CSSF DORA inspection.
Luxgap practice: we automatically reconcile your existing 22/806 register with the DORA Article 8 mapping and surface the gaps (digitalised functions present in the IT estate but missing from the register) before the CSSF detects them.
