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On March 24 2025, the European Commission (EC) adopted the final draft Delegated Regulation setting out Regulatory Technical Standards (RTS) for subcontracting ICT services supporting critical or important functions under the...more
EU national supervisory authorities will collect the Register of Information (ROI) pursuant to the EU’s Digital Operational Resilience Act (DORA) from in scope financial entities in April 2025, with the reference date set as...more
What has happened: On 21 January 2025, the European Commission sent a letter to the Chair of the Joint Committee of the ESAs with its decision to reject the draft Regulatory Technical Standards (“RTS”) on subcontracting...more
The EU Digital Operational Resilience Act (“DORA”) is due to apply from 17 January 2025. It is designed to ensure regulated financial entities can withstand and recover from technology issues such as cyber events and...more
The Digital Operational Resilience Act 2022/2554 (DORA) is a European regulation that will come into force on January 17, 2025. The regulation aims to strengthen the digital operational resilience of the financial sector...more
The European Supervisory Authorities have published a joint statement on the application of the EU Digital Operational Resilience Act. The ESAs emphasise that as DORA does not provide for a transitional period, it is...more
Long IT sub-contracting chains can make it hard for financial institutions to understand the vulnerabilities in their IT estate and the location of key functions (where these may be located in entities who do not have a...more
The Personal Information Protection Act ("PIPA") comes into full force on 1 January 2025. All organisations in Bermuda are expected to be in compliance with it by that date – time is running out! The Privacy Commissioner...more
The announcement in 2021 of the intention to implement new rules directly targeting the types of tech service provider relied on by most financial institutions may be a necessary corrective given the heavy market...more
Following the European Council's approval last week, the Digital Services Act (DSA) has been officially adopted, starting the countdown to the law’s entry into force later this year. The DSA builds on the Electronic Commerce...more