Position paper - Consultation response: Second batch of policy products under the Digital Operational Resilience Act

In light of the European Supervisory Authorities (ESAs)’ joint consultation on the second batch of Level 2 policy products under the Digital Operational Resilience Act (DORA), this paper provides concrete suggestions and amendments to strengthen the principle of proportionality and legal certainty. In order to ensure robust operational resilience for the European financial sector, the ESAs should consider refinements of the framework for subcontracting, threat-led penetration testing, major incident reporting and oversight harmonisation.