ECSDA Response to ESMA on Outsourcing to Cloud Services Providers
On 31 August 2020, ECSDA responds to the ESMA Consultation Paper on Outsourcing to Cloud Services Providers.
The European Central Securities Depositories Association (ECSDA) welcomes the consultation paper on Draft Guidelines on Outsourcing to Cloud Service Providers.
ECSDA believes that some elements in this consultation would benefit from alignment with the EBA Outsourcing Guidelines, while others would benefit from clarification, given the specific context of CSDs as FMI. The association considers that a single set of guidelines that would apply to all outsourcing relationships and thus integrate both cloud and non-cloud outsourcing would be the ideal methodology to follow if it is taken into account that only some CSDs are subject to the EBA Guidelines. Careful consideration needs to be given to the interaction between the European Authorities guidelines on outsourcing to CSPs and eventual related legislative developments. Those legislative efforts of enhancing coherence would gather our support, as they would alleviate the industry from some significant concerns related to contract management.