The EACB welcomes the opportunity to comment on the ESAs Discussion Paper aiming to feed the reflections for the technical advice to further specify the criteria for critical ICT third-party service providers (CTPPs) and determine the fees levied on such providers under the Regulation on Digital Operational Resilience for the Financial Sector (DORA).
We appreciate the ESAs’ efforts to involve market participants in a transparent manner for the development of the technical advice to the European Commission, however we regret that the consultation period was too short to develop feedback with respect to certain elements of the Discussion Paper, particularly on the identification of further metrics and information sources.
We would also like to warn against cost hikes for ICT TPPs that could be derive from the elements of the new framework to be specified: we recommend to carefully balance costs and benefits of new requirements/financial overheads. Any increase without objective justification or actually leading to improved resilience should be avoided.