EvidenceSheet

Art.28 ICT third-party risk: general principles

Financial entities manage ICT third-party risk as part of ICT risk inside the ICT risk management framework, remain fully responsible for their obligations when they use ICT services, and apply proportionality according to the nature and importance of ICT dependencies and the criticality of each service. They keep a register of information on all ICT service arrangements at entity, sub-consolidated and consolidated level, distinguishing those supporting critical or important functions; report at least yearly to the authority on new arrangements, provider categories, contract types and services; provide the full register or sections of it on request; and inform the authority in time of planned arrangements for critical or important functions. Before contracting they assess criticality, supervisory conditions, risks including concentration, due diligence and conflicts of interest; they use only providers meeting appropriate security standards, set risk-based audit frequencies, ensure contracts can be terminated in the listed cases, and keep tested exit strategies for services supporting critical or important functions. The ICT third-party risk strategy with its policy on critical or important functions (Art. 28(2)) is required only of entities other than Article 16(1) entities and microenterprises.

Source: DORA (Regulation (EU) 2022/2554), Art.28. The statement above is our statement of the clause, read from the published text and cited so you can check it against the official text, not the instrument verbatim. Open DORA (Regulation (EU) 2022/2554) in the compliance library.

Applies to the financial entities listed in Article 2. Many duties are lighter or absent for microenterprises and for the entities in Article 16(1); each statement says where. Article 19 carries the reporting clocks of Delegated Regulation (EU) 2025/301, Article 5.

5
artefacts
0
held by a system
2
at each review
hard
to go live
Vendor register / contract repository
where the evidence lives
teal = a system already holds it · olive = produced at each review. To go live: easy when half or more of the artefacts are already held by a system, moderate from a quarter to a half, hard below a quarter.

These are the artefacts auditors commonly ask for on this requirement, our guidance rather than text from the standard. Your assessor decides what is sufficient in your context, and asks for samples across the period when a report covers one.

system holds itEvidence a system already holds

none for this control

periodic reviewEvidence produced at each review

  • Yearly report to the competent authority on new arrangements, provider categories, contract types and services, with submission confirmation · Regulator portal / correspondence
  • Pre-contract assessment files covering criticality, supervisory conditions, risk and concentration, due diligence and conflicts of interest · Vendor register / contract repository

governing documentDocuments that govern the control

  • Register of information on all ICT service arrangements at entity and consolidated level, flagging critical or important functions · Vendor register / contract repository
  • Tested exit plans for services supporting critical or important functions · Vendor register / contract repository
  • Board-approved ICT third-party risk strategy and policy (entities other than Article 16(1) entities and microenterprises) · Vendor register / contract repository

First move

No system holds this evidence for you: it is people and documents. Reminders and routing to the owner still save time. Put the document under version control with an owner and review date, and log each review as a record with reviewer and date.

Common gaps auditors find

Do this for your whole sheet

Paste the rows you run your controls from and get this mapping for every control at once, with the periodic-review ones flagged and a first move per row. No account for the first run.

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Art.27 Requirements for testers for the carrying out of TLPT · Art.29 Preliminary assessment of ICT concentration risk at entity level