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ARTICLE · 01 AUGUST 2025

Uniform Standards For ICT Subcontracting In EU Financial Sector: New Obligations

Jones Day
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The Background: The EU has introduced Delegated Regulation (EU) 2025/532, establishing binding regulatory technical standards ("RTS") for the subcontracting of information and communications technology ("ICT") services supporting critical or important functions within financial entities

GlobalPrivacy
Marco Frattini
Marco Frattini
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
Undine Von Diemar
Undine Von Diemar
Céline Hoffmann
Céline Hoffmann
+1 more
Author LinkedIn connections

In Short

The Background: The EU has introduced Delegated Regulation (EU) 2025/532, establishing binding regulatory technical standards ("RTS") for the subcontracting of information and communications technology ("ICT") services supporting critical or important functions within financial entities. This regulation supplements the Digital Operational Resilience Act ("DORA") and aims to harmonize risk management and oversight of ICT outsourcing across the EU financial sector.

The Result: The new standards impose detailed obligations on financial entities, including comprehensive risk assessments, group-wide application, enhanced due diligence, and strict contractual requirements for ICT subcontracting. The regulation will be directly applicable in all EU Member States from 22 July 2025, requiring immediate action from financial institutions to ensure compliance.

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