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ARTICLE · 12 NOVEMBER 2026

Beyond Outsourcing - Third-Party Risk Management

Dillon Eustace
Dillon Eustace
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Dillon Eustace

Dillon Eustace

Dillon Eustace is one of Ireland’s leading law firms focusing on asset management and investment...

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The European Banking Authority and the Central Bank of Ireland have published new frameworks that fundamentally reshape how financial institutions must manage relationships with third-party service providers. These guidelines represent a decisive shift from traditional outsourcing oversight to comprehensive third-party risk management, with heightened requirements for arrangements supporting critical or important functions. Financial entities across Europe and Ireland now face significant implementation cha

European UnionFinance and Banking
Keith Waine
Keith Waine
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On 18 September 2026, the European Banking Authority (EBA) published its final Guidelines on the sound management of third-party risk regarding non-ICT services (EBA Guidelines). The EBA Guidelines will repeal the EBA Guidelines on outsourcing arrangements published in 2019 (2019 Guidelines).

Three weeks later, on 8 October 2026, the Central Bank of Ireland (Central Bank) published Consultation Paper 173 (CP173). CP173 seeks views on proposed Guidance on Good Practices for the Sound Management of Third-Party Risks (Draft Guidance). Once finalised, the Draft Guidance will replace the Central Bank's Cross-Industry Guidance on Outsourcing published in December 2021 (2021 Guidance).

Taken together, these publications move both the European and the Irish framework away from the traditional concept of outsourcing and towards the wider risk management of all third-party dependencies. We summarise below the key changes and their likely impact on our clients.

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