Position paper - European Supervisory Authorities' joint advice on delegated acts under DORA

In light of the European Supervisory Authorities’ Joint Advice, the European Commission should ensure that the scope of the oversight framework will not go beyond what is necessary in order to achieve the objectives laid out in Digital Operational Resilience Act (DORA). To better comply with the new rules, the industry needs more clarity regarding the indicator-based approach and methodology. In addition the inclusion of the level of inherent criticality of ICT services (as per indicator 3.1) is highly concerning as it implies a significant extension, which is not based on the Level 1 legislation. Furthermore, challenges remain around oversight fees. For instance, the Joint Advice upholds a disproportionate fall-back option, which may violate the boundaries set by the DORA.

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