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ARTICLE · 10 NOVEMBER 2025

New ECB Guide On Outsourcing Cloud Services To Cloud Service Providers

Jones Day
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Although formally non-binding, the ECB states that JSTs will use the ECB Guide on outsourcing cloud services to cloud service providers as a benchmark in supervisory assessments, which sets expectations that companies will adopt the recommended practices.

European UnionFinance and Banking
Michael R. Fischer
Michael R. Fischer
Michèle Grégoire
Michèle Grégoire
Philippe Goutay
Philippe Goutay
Jörg Hladjk
Jörg Hladjk
Olivier Haas
Olivier Haas
Iván Martín-Barbón
Iván Martín-Barbón
Mauricio Paez
Mauricio Paez
Undine Von Diemar
Undine Von Diemar
Céline Hoffmann
Céline Hoffmann
+1 more
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In Short

The Situation: On 16 July 2025, the European Central Bank ("ECB") published a non-binding Guide clarifying supervisory expectations for institutions outsourcing cloud services.

The Result: The Guide translates third-party risk rules of the Digital Operational Resilience Act (2022/2554/EU, "DORA") and the Capital Requirements Directive (2013/36/EU, "CRD") into detailed recommended practices on governance, risk assessment, resilience, security, oversight, and exit management. It explicitly draws on the ECB's supervisory experience and DORA Level 2 Regulatory Technical Standards (2024/1773 and 2024/1774).

Looking Ahead: Directly supervised banks are expected to benchmark their cloud outsourcing arrangements against the Guide without delay and document remediation plans to avoid supervisory findings in upcoming Joint Supervisory Teams' ("JSTs") reviews and on-site inspections.

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