Outsourcing is often sold internally as speed: “let’s plug in a provider and move on.”
However, under the MFSA’s outsourcing expectations, the moment a third party supports a critical or important function, the conversation changes. You are no longer buying a service; you are creating a dependency that must be governable, auditable, and exitable.
The MFSA guidance is explicit about why it cares: regulated firms increasingly rely on ICT-enabled critical/important functions delivered remotely by third parties (often cloud), which expands cyber exposure and complicates supervisory oversight.
So, the real question isn’t “can we outsource this?”
It’s “can we still prove control after we outsource it?”
