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DORA ICT Subcontracting RTS Published DORAIntellectual PropertyTelecoms, Media & Technology

DORA ICT Subcontracting RTS Published

Following the European Commission’s earlier rejection, the Regulatory Technical Standards (RTS) on ICT Subcontracting have been published in the EU Official Journal on 2 July 2025. The RTS will enter into force 20 days after publication, which means that they will come into effect on 22 July 2025. Financial entities and ICT providers must ensure to update their contractual arrangements to fulfil the conditions set out in the RTS to ensure compliance by 22 July 2025. To receive updates on this important development and related news please visit our website and consider subscribing to our newsletter. This document does not purport…
Mamo TCV Advocates
3rd July 2025
Rejected!
European Commission Rejects Draft Regulatory Technical Standards on ICT Subcontracting DORATelecoms, Media & Technology

European Commission Rejects Draft Regulatory Technical Standards on ICT Subcontracting

The European Commission has communicated its rejection of the draft Regulatory Technical Standards (RTS) on subcontracting ICT services supporting critical or important functions supplementing the Digital Operational Resilience Act (DORA).  In its communication, the Commission held that the European Supervisory Authorities (ESAs) exceeded their mandate under Article 30(5) of DORA (which came into effect on 17 January 2025) by introducing requirements not specifically linked to the conditions for subcontracting in Article 5 of the RTS. The Commission has made it clear that Article 5 and the related recital 5 of the draft RTS must be omitted from the draft RTS…
Mamo TCV Advocates
31st January 2025
Furthering MiCAR in Malta by Chapter 647
Fintech Insights #8 –
Furthering MiCAR in Malta by Chapter 647 FinTech

Fintech Insights #8 –
Furthering MiCAR in Malta by Chapter 647

Chapter 647 of the Laws of Malta, titled the Markets In Crypto-Assets Act (hereinafter referred to as “Chapter 647”), integrates all aspects of Regulation (EU) 2023/1114 of the European Parliament and Council on markets in crypto-assets (“MiCAR”). MiCAR regulates the issuers of asset-referenced tokens (“ARTs”), electronic money tokens (“EMTs”), other types of tokens, as well as the conduct of crypto asset service providers (“CASPs”). Malta’s presidential assent to Chapter 647 was given on the 5th of November 2024 through  Act No. XXXVI of 2024 (“Act 36 (2024)”); and it was promulgated on the same day. Similar to MiCAR, Act 36…
Mario Mizzi
12th November 2024
Key representing digital resilience
Status of DORA Regulatory Technical Standards (“RTS”) DORAFinTechTelecoms, Media & Technology

Status of DORA Regulatory Technical Standards (“RTS”)

Regulation (EU) 2022/2554 of the European Parliament and of the Council of 14 December 2022 on digital operational resilience for the financial sector ( “DORA”) establishes the EU legislative framework for enhancing digital resilience within the EU’s financial industry. Enforcement commences on 17th January 2025 and the EU Commission is tasked with issuing Regulatory Technical Standards (“RTS”) which supplement DORA. The EU Commission publishes the RTS in the Official Journal as Commission Delegated Regulations, but they are largely based on the input of the European Supervisory Authorities (“ESA”) which comprise of ESMA, EBA and EIOPA. The draft RTS submitted to the European…
Mario Mizzi and Nicole Bonett
17th September 2024