Comments
1st of April 2026

Comments on the Commission guidance on the application of the Cyber Resilience Act (CRA)

German Banking Industry Committee
Thomas Schlüter
Thomas Schlüter

The Commission guidance can help better understand the CRA requirements. In this context, there are still a number of questions, which we explain in the attached appendix. We also support the issuance of further guidelines under Article 26 of the CRA regarding the interaction between the CRA and Regulation (EU) 2022/2554 on digital operational resilience for the financial sector (DORA). As we have already noted in previous comments we call for clear exemption from the CRA for financial entities subject to DORA.

DK zu den Leitlinien der Europäischen Kommission zur Anwendung des Cyber Resilience Act

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Comments
15th of July 2026

GBIC comments on the EBA Discussion paper

Simplification and assessment of the credit risk framework

The German Banking Industry Committee welcomes the initiative of the European Banking Authority (EBA) to explore possible avenues for simplifying the existing credit risk framework.