Question ID: DORA 248 - 3376
Regulation Reference: (EU) 2022/2554 - Digital Operational Resilience Act (DORA)
Topic: Other DORA topics
Article: 3(60, 63 et 64)
Status: Rejected
Date of submission: 03 Jul 2025
Question
With regard to ancillary insurance intermediaries, should the thresholds for determining whether an entity is a micro, small or medium-sized enterprise, as set out in Article 3(60), (63) and (64), be based on the turnover generated exclusively by insurance activities or on the entity's total turnover?
Background of the question
These obligations were primarily designed for financial entities, and the inclusion of revenue from non-financial activities appears inconsistent with the spirit of the Regulation. Moreover, since ancillary insurance intermediaries that are exempted are not subject to DORA (see Q&A - 3074 - DORA096), this could create a competitive imbalance and incentivize regulatory arbitrage between exempted and non-exempted AIIs."
EIOPA answer
This question has been rejected because the matter falls within the scope of Q&A 099 and Q&A 237 respectively.