Question
Should a credit bureau apply DORA directly, similar to any other financial entity, as an Account Information Service Provider or AISP, or should the CRA apply DORA indirectly, as an ICT third-party provider?
Background on the question
It is not uncommon for credit bureaus to possess a license allowing them to offer Account Information Services (AISP) under Article 33(1) of Directive (EU) 2015/2366. If it is assumed (see a previous question from ACCIS) that the services provided by credit bureaus typically fall within the category of ICT services under DORA, there may be an instance of dual application of DORA, both as AISP (article 2.1.c) and ICT Services Provider (article 2.1.u)
Answer
This question has been rejected because the matter it refers to is in the process of being answered in Q&A DORA 30 (EIOPA Q&A 2999)