Position paper - Consultation response on the delegated acts on criticality designation criteria and on oversight fees under the Digital Operational Resilience Act

In light of the European Commission’s consultation on the delegated acts on criticality designation criteria and on oversight fees under the Digital Operational Resilience Act (DORA), this paper suggests concrete amendments to strengthen the principle of proportionality and legal certainty. In order to ensure robust operational resilience for the European financial sector, the Commission should adopt a clear assessment approach to the criticality designation. Furthermore, a proportionate consideration of the applicable turnover for oversight fee calculation would better secure the funding of the incoming oversight regime.

Please read more in our consultation response below.