Question
Does a critical external / third-party provider to a service provider which is not indicated as relevant and listed in template Z 01.00 have to be reported in template Z 08.00?
Background on the question
In line with Article 4(2), points (a) and (h) of Implementing Regulation (EU) 2018/1624, our understanding is that critical external/third party-providers to an institution (listed in Z 01.00) have to be reported in Z 08.00. Whereby receiving service providers not named in Z 01.00 should not report their critical external/third party providers in Z 08.00, i.e. critical external services to the institution (institution is named in Z 01.00) are to be reported in Z 08.00, critical external services to a service provider that is not listed in Z 01.00 does not have to be reported in Z 08.00. This understanding is also reflecting that an unregulated service provider does not have critical functions, but Z 08.00 is asking for the related critical functions.
Answer
This question has been rejected because the issue it deals with is already explained or addressed in Article 4(2), point (h), of Regulation (EU) 2018/1624, as well as Annex II, paragraph 48, thereto.For further information on the purpose of this tool and on how to submit questions, please see 'Additional background and guidance for asking questions'.