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European Insurance and Occupational Pensions Authority
 

DORA 256 - 3398

Q&A

Question ID: DORA 256 - 3398

Regulation Reference: (EU) 2022/2554 - Digital Operational Resilience Act (DORA)

Topic: Other DORA topics

Article: 3(21)

Status: Rejected

Date of submission: 29 Jul 2025

Question

Based on the definition of DORA Article 3(21) and DORA030 - 2999, how can the answer regarding the classification of ancillary services as financial services be interpreted in accordance with DORA and in the case of contractual triangular relationships?

Background of the question

The above-mentioned reply stated: "The same rationale applies to ancillary services provided by an entity, depending on whether such ancillary services are regulated financial services or a service inseparable from, indivisible from, preparatory or necessary for the provision of a regulated financial service, and are not provided in a standalone manner." This allows for interpretations based on the following questions: What role does it play in classifying a service as a regulated financial service if the contracting party and the provider of the service are different? What role does it play if either only the contracting party or the provider is a regulated financial undertaking, or if IT infrastructure (already covered by a DORA agreement) by another ICT provider is used for a service?

EIOPA answer

This question has been rejected because it is unclear.