IT-Anforderungen an Finanzunternehmen in Deutschland – ein Überblick über den regulatorischen Rahmen IT Requirements for Financial Institutions in Germany – an overview of the regulatory framework
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IT Requirements for Financial Institutions in Germany – an overview of the regulatory framework

IT regulation in the financial sector is becoming increasingly complex. With DORA, the FinmadiG, the NIS 2 Implementation Act, GDPR, the Cyber Resilience Act, the Data Act and the AI Act, financial institutions face far-reaching requirements regarding digital resilience, third-party risk management and governance. This article provides a structured overview of the current regulatory framework in Germany and at EU level.
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KI-Regulierung in der Praxis: Was die Aufsicht zu KI im Finanzsektor wirklich sehen will | ALLES LEGAL #126 AI Regulation in Practice
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AI Regulation in Practice: What Supervisors Really Expect to See from AI in the Financial Sector | ALLES LEGAL #126

Annerton partner Josefine Spengler explains how supervisory authorities assess AI systems in the financial sector in practice. AI is not treated as a regulatory special case but as an ICT system embedded within existing frameworks, particularly DORA. The focus lies on governance, accountability, traceability and ongoing monitoring. The interaction between DORA and the EU AI Act adds further complexity. The key takeaway: AI is not merely an IT issue – it is a management responsibility.
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Von Outsourcing zu Third Party Arrangements: Die neuen EBA-Leitlinien zum Drittparteienmanagement • Teil 1: Überblick über die wichtigsten Neuerungen
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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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From Onboarding to Offboarding: Lifecycle Management of ICT Third-Party Relationships under DORA 2
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From Onboarding to Offboarding: Lifecycle Management of ICT Third-Party Relationships under DORA

The DORA Regulation (EU) 2022/2554 obliges financial institutions to manage their ICT third-party relationships in a structured way across the entire lifecycle – from selection to exit. For FinTechs, this means that ad hoc purchases of IT services are a thing of the past. Instead, documented and auditable processes are required, taking into account risks, supervisory requirements, and exit strategies.
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