ALFI responds to ESMA on outsourcing to cloud service providers

The guidelines’ purpose is to provide guidance on the outsourcing requirements applicable to financial market participants when they outsource to cloud service providers. In particular, they aim to help firms and competent authorities identify, address and monitor the risks and challenges that arise from cloud outsourcing arrangements.

The proposed guidelines set out:

• The governance, documentation, oversight and monitoring mechanisms that firms should have in place;
• The assessment and due diligence which should be undertaken prior to outsourcing;
• The minimum elements that outsourcing and sub-outsourcing agreements should include;
• The exit strategies and the access and audit rights that should to be catered for;
• The notification to competent authorities; and
• The supervision by competent authorities.

The ALFI response is available in pdf.