LLegal
Von Outsourcing zu Third Party Arrangements: Die neuen EBA-Leitlinien zum Drittparteienmanagement • Teil 1: Überblick über die wichtigsten Neuerungen
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  • 7 minute read

From Outsourcing to Third Party Arrangements: The New EBA Guidelines on Third-Party Risk Management 1/2

On 8 July 2025, the European Banking Authority (EBA) published a new consultation paper on the EBA Guidelines for third-party risk management. The draft goes well beyond the previous Outsourcing Guidelines from 2019. The objective is to establish a harmonised European framework for managing third-party risks, aligned in particular with the Digital Operational Resilience Act (DORA). Part 1 of the analysis highlights the key innovations and main content; a practical assessment will follow in Part 2.
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FFinTech
The Determining Role of the Schufa Score in Third-Party Decisions 2
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  • 5 minute read

The Determining Role of the Schufa Score in Third-Party Decisions

Whether the Schufa score is decisive for third-party credit decisions has, since the CJEU ruling of 7 December 2023 (C-634/21), determined whether its mere calculation qualifies as an automated decision within the meaning of Article 22(1) GDPR. The CJEU made it clear that this cannot be assumed in general but must instead be assessed by national courts on a case-by-case basis. Since then, uncertainty has prevailed as to how the requirement of “decisiveness” should be interpreted.
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