GBIC-response to EBA consultation on guidelines on the sound managent of third-party risk

The German Banking Industry Committee (GBIC) welcomes the aim of aligning the EBA Guidelines on Third-Party Risk Management with DORA to enhance consistency and reduce complexity. However, the draft introduces unnecessary duplication, an arbitrary ICT/non-ICT divide, and overly detailed requirements. The DK calls for a clearer, risk-based and proportional approach aligned with DORA definitions and documentation standards, focusing on material risks and practical feasibility. Consistent implementation across Member States is essential to avoid national gold-plating and ensure genuine harmonization.