Bitkom supports the EU’s efforts in strengthening and harmonizing ICT security and digital resilience of financial services across Europe. We welcome the holistic approach targeting the financial services eco system along its entire value chain, including critical third-party providers (CTPPs). According to Bitkom, this allows to (a) allocate responsibilities among market participants across the value chain more efficiently and (b) facilitate scalability for CTPPs. In the light of ongoing negotiations, we ask to put the focus on resolving existing issues from the EU Commission’s proposal rather than adding further complexity, which may run contrary to the very goals of DORA.
