On 16 July 2025, the European Central Bank (ECB) published a guide on outsourcing cloud services to cloud service providers.

The publication of the guide follows an earlier public consultation and the ECB has also published a feedback statement which provides an overview of the comments received and the ECB’s assessment of them. The final version of the guide more clearly differentiates the requirements set out in Digital Operational Resilience Act (DORA) from the good practices recommended by the ECB. It also clarifies the way in which the principle of proportionality is applied.

Photo of Nikolai de Koning Nikolai de Koning

Nikolai de Koning is a financial services lawyer (advocaat) based in Amsterdam. Nikolai is experienced in financial services and banking law, as well as in data privacy (protection). He is experienced in advising on regulatory and compliance aspects relevant to financial…

Nikolai de Koning is a financial services lawyer (advocaat) based in Amsterdam. Nikolai is experienced in financial services and banking law, as well as in data privacy (protection). He is experienced in advising on regulatory and compliance aspects relevant to financial institutions, such as insurance companies, investment firms, clearing institutions and central counterparties. Nikolai also advises on Dutch licence and notification requirements and he assists companies in their licence or notification processes with the Dutch financial regulators. He also specialises in privacy issues arising out of online products, data protection and e-commerce.