Recital 27
Digital Operational Resilience Act · UE 2022/2554
| (27) | Financial entities’ reliance on the use of ICT services is partly driven by their need to adapt to an emerging competitive digital global economy, to boost their business efficiency and to meet consumer demand. The nature and extent of such reliance has been continuously evolving in recent years, driving cost reduction in financial intermediation, enabling business expansion and scalability in the deployment of financial activities while offering a wide range of ICT tools to manage complex internal processes. |
In Luxembourg, the CSSF anticipated the spirit of recital 27 well before DORA through CSSF circular 22/806 on outsourcing arrangements, which already requires prior notification for material ICT outsourcing and an up-to-date register. DORA reinforces this framework without replacing it: Luxembourg financial entities remain subject to the dual circular 22/806 + DORA requirement, with the CSSF as single competent authority.
Luxgap practice: align your DORA article 28(3) register on the CSSF 22/806 notification format from day one, to avoid duplicate entry and ensure consistency during a joint inspection.
