Question
Within Title II, Section 3, Recital 28 Guidelines on outsourcing an exemption what should not be considered an outsourcing is given. Under this exemption can we consider that purchases of goods e.g., standard software or hardware without customization or integration into critical processes, are not outsourcing? For example if the SaaS application is used solely for non-critical, non-banking functions (e.g., HR training platforms, marketing tools), and does not impact the institution’s operational resilience or critical functions, can it be treated from a bank perspective as purchase of goods that fall outside the EBA guidelines on outsourcing arrangements scope?
Background on the question
Title II, Section 3, Recital 28
Answer
This question has been rejected because the issue it deals with is already explained or addressed in paragraph 28(g) of theEBA Guidelines on outsourcing arrangements.