Position papers

  • EAPB response to ESAs DORA major incident reporting consultation

    Banking supervision 4 March 2024

    The European Supervisory Authorities (EBA, EIOPA and ESMA) have published the second batch of Consultation Papers on the mandates stemming from the Digital Operational Resilience Act (DORA) with the aim to collect market participants’ feedback on the proposed Draft Regulatory Technical Standards on the content of the notification and reports for major incidents and significant cyber threats.

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  • EAPB response to ESAs TLPT consultation

    Banking supervision 4 March 2024

    The European Supervisory Authorities (EBA, EIOPA and ESMA) have published the second batch of Consultation Papers on the mandates stemming from the Digital Operational Resilience Act (DORA) with the aim to collect market participants’ feedback on the proposed Draft Regulatory Technical Standards on elements related to threat-led penetration tests.

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  • EAPB response to ESAs DORA subcontracting consultation

    Banking supervision 4 March 2024

    The European Supervisory Authorities (EBA, EIOPA and ESMA) have published the second batch of Consultation Papers on the mandates stemming from the Digital Operational Resilience Act (DORA) with the aim to collect market participants’ feedback on the proposed Draft Regulatory Technical Standards to specify the elements which a financial entity needs to determine and assess when subcontracting ICT services supporting critical or important functions as mandated by Article 30(5) of Regulation (EU) 2022 /2554.

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  • EAPB response to call for evidence GDPR

    8 February 2024

    The GDPR establishes a consistent legal framework throughout the EU, ensuring a high standard of data protection, which is generally deemed successful in the banking sector. However, it was noted by our members that ensuring GDPR compliance presents significant challenges for medium-sized and small companies, lacking the financial means and organizational capacity to employ all necessary experts, including DPOs and CISOs.

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  • EAPB call for adaptation of SME definition

    State aid, Sustainable finance 7 December 2023

    EAPB highly welcomes the SME relief package and in particular the announcement that, by the end of 2023, the EC will analyse the impact of high inflation and longer-run increases in productivity with a view to raising - when justified - the financial thresholds of the current SME definition and developing a harmonised definition for small mid-cap companies.

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