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ARTICLE · 03 FEBRUARY 2025

DORA Compliance: What Is An ICT Service?

Arthur Cox
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The European Commission has now published its long-awaited additional guidance on how to determine whether a service received from a financial entity should be classified as an ‘ICT Service' within the meaning of DORA.

IrelandFinance and Banking
Ciaran Flynn
Ciaran Flynn
Ian Duffy
Ian Duffy
Ciara Anderson
Ciara Anderson
Sarah Thompson
Sarah Thompson
Siobhan McBean
Siobhan McBean
Denise Murray
Denise Murray
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The European Commission has now published its long-awaited additional guidance on how to determine whether a service received from a financial entity should be classified as an 'ICT Service' within the meaning of DORA.

Financial Services vs. ICT Services

The definition of 'ICT services' under DORA is intentionally broad, and encompasses digital and data services provided through ICT systems on an ongoing basis. However, given that nearly all services have an ICT component, the question outstanding has been whether DORA should also be applied to digitally-backed financial services.

The European Commission has now addressed this question, setting out that in order to be considered an ICT Service for the purposes of DORA and the Register of Information, the following two tests must be applied to each service received:

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This article contains a general summary of developments and is not a complete or definitive statement of the law. Specific legal advice should be obtained where appropriate.

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