Comments on Draft EBA Guidelines on Outsourcing
On 22 June 2018, the EBA published a consultation paper on its Guidelines on Outsourcing arrangements (EBA/CP/2018/11). The German Banking Industry Committee (GBIC) appreciates the opportunity to comment. The GBIC believes that the obligations for institutions proposed in the Draft guidelines go too far overall. Inter alia, the requirements do not distinguish sufficiently between the outsourcing of critical and of non-critical functions. There is a risk that institutions will no longer be able to exploit the opportunities offered by outsourcing because of the high administrative effort.