RegTech · EBA Third-Party Risk · DORA

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§ Outsourcing register

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§ Regulatory update — 2025 / 2026

The EBA is replacing its 2019 Outsourcing Guidelines.

The European Banking Authority (EBA) is replacing the 2019 Outsourcing Guidelines (EBA/GL/2019/02) with comprehensive new Guidelines on the sound management of third-party risk.

The regulatory focus shifts from a narrow definition of "outsourcing" to a full lifecycle framework covering all non-ICT and general third-party arrangements — running in parallel with the Digital Operational Resilience Act (DORA), which governs ICT-specific risk.

JUL 2025
Consultation launched
The EBA published draft guidelines and opened the consultation phase.
2026
Finalisation & adoption
Finalisation and adoption milestones progress through 2026.
~2 YEARS
Transition period
An anticipated grace period to update contracts and inventories.
01 · SCOPE

Broadened scope

Extends beyond traditional outsourcing and credit institutions to all third-party arrangements — including intragroup — and to entities such as payment and e-money institutions and mortgage creditors.

02 · DORA

DORA alignment

Separates ICT services, governed exclusively by DORA, from non-ICT services — keeping risk-management standards consistent across every vendor dependency.

03 · REGISTERS

Unified registers

Introduces frameworks for integrated third-party information registers that align non-ICT documentation with existing DORA ICT registers.

04 · TIMELINE

Two-year runway

Following the July 2025 consultation, financial entities are expected to have roughly two years to bring contracts and inventories into line.

The platform

The database purpose-built for contract management and outsourcing registers.

ENFORMITY supports the full contract-documentation lifecycle across your organisation.

01 — CAPTURE

Document & capture

  • Contract-type–driven workflows
  • Involve departments and groups across the process
  • Full-text extraction from source documents for a precise, point-accurate search index
02 — MANAGE

Manage at scale

  • Mass editing across large contract portfolios
  • Export for archiving, FMA, BaFin and audits
  • Contract tagging and personalised interfaces
  • Granular, role-based user model
  • Complete audit trail of every master-data change
03 — AUTOMATE

Review & automate

  • Review workflows and structured sign-off
  • Termination-option and notice-period tracking
  • Automated master-data updates from internal and external sources
  • Time-triggered actions and alerts

ENFORMITY in detail

ENFORMITY centrally maps all existing intra- and intercompany contracts, service level agreements and outsourcing arrangements — where relevant, across a group or an institutional protection scheme:

  • Model and maintain contract structures across their full term — and, where needed, beyond expiry.
  • Track amendments and replacements, and visualise contract hierarchies.
  • Retain historical entries in line with regulatory documentation requirements.
  • Record contract parties with every required attribute — and, within GDPR limits, their contacts.
  • Automatically refresh the master data of contract parties.
  • Multi-tenancy: run one central register for several institutions within a group.
  • Configure every required data field and map it to critical or non-critical banking processes per EBA / FMA guidelines.
  • Filter and export data on demand for the competent authority.
  • Support outsourcing analysis and store the underlying due-diligence assessment.
The outsourcing register — 30+ defined information points

Your outsourcing register, exactly by the book.

Beyond core contract management, ENFORMITY captures the 30+ specific information points defined for the outsourcing register. Every field is configurable and mapped to critical or non-critical banking processes per EBA and FMA guidelines.

REF.01

Contract dates

Start date, next renewal date, expiry date and notice periods.

REF.02

Service description

Description of the outsourced service, with category assignment.

REF.03

Data & GDPR

What data is outsourced, whether personal data is transferred and to which provider.

REF.04

Location & law

Country or countries where the service is performed, with the applicable law.

REF.05

Criticality

Whether the outsourced function is considered critical or important.

REF.06

Last assessment

Date of the most recent criticality or importance assessment.

REF.07

Cloud services

Cloud service and deployment model, and the locations where data is stored.

+22
MORE FIELDS
Deployment & integration

Fits seamlessly into your enterprise IT.

Governed by an intuitive, flexible role model with granular permission control.

The NFORMITY contract management dashboard
ENFORMITY outsourcing register with risk flags and reporting

Fully responsive

A responsive UX/UI: the application works on the desktop and on every mobile device.

Hosting options

Run it in a public or private cloud, or on-premise in your own data centre.

Deep integration

Integrates with enterprise systems such as directory services for single sign-on.

Highly configurable

Value lists, jobs and processes are freely configurable and adapt to your requirements.

Customers

Trusted by financial institutions and their advisors.

A range of customers rely on ENFORMITY. A few of them, in their own words.

“

ENFORMITY is the ideal solution for our bank's requirements in group-internal SLA contract management.

Günter Kratschmar
UniCredit Bank Austria AG
“

The project team ensured fast, agile delivery — from specification all the way through to running the solution in production.

Christoph Lischka
card complete
“

ENFORMITY is the leading contract-management solution — one we are very happy to recommend to our clients.

Philipp Lindner
Hotter & Partner Unternehmensberatung GmbH
Get in touch

Request a test environment.

Have questions about the platform? Get in touch and request test access. We are also happy to arrange a reference call with one of our customers.

Emailoffice@enformity.com
Vienna, AustriaWollzeile 24, 1010 Vienna

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