EBA Outsourcing Guidelines – Upcoming Application Date

As further set out in our previous client briefing, the European Banking Authority ("EBA") Guidelines on outsourcing arrangements (the "Guidelines") apply to institutions within the EBA's regulatory scope, including credit institutions, certain investment firms, payment institutions and e-money institutions ("In-Scope Entities").

The Guidelines apply from 30 September 2019. Following that date, In-Scope Entities should have a Guidelines-compliant outsourcing framework in place. Additionally, all outsourcing arrangements entered into, reviewed or amended after that date must comply with the requirements of the Guidelines. All outsourcing arrangements must be compliant by 31 December 2021.