As further set out in our previous client briefing, the European Banking Authority ("EBA") Guidelines on outsourcing arrangements (the "Guidelines") apply to institutions within the EBA's regulatory scope, including credit institutions, certain investment firms, payment institutions and e-money institutions ("In-Scope Entities").
The Guidelines apply from 30 September 2019. Following that date, In-Scope Entities should have a Guidelines-compliant outsourcing framework in place. Additionally, all outsourcing arrangements entered into, reviewed or amended after that date must comply with the requirements of the Guidelines. All outsourcing arrangements must be compliant by 31 December 2021.
In-Scope Entities should commence their implementation planning for the Guidelines as soon as possible, to the extent they have not already done so, to ensure their proper implementation in advance of the 30 September application date.
Walkers is assisting In-Scope Entities on assessing and amending their outsourcing frameworks to ensure compliance with the Guidelines in advance of 30 September, as well as to take account of the Central Bank of Ireland's Discussion Paper on Outsourcing, November 2018.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.