Map without delay critical TIC dependencies on extra-European hyperscalers and arbitrate between DORA-compliant contractual remediation, migration to qualified sovereign cloud, or hybrid architecture with tested exit strategy.
- Who
- European financial institutions and credit institutions in the eurozone using critical third-party TIC providers (non-EU hyperscalers) for cloud services or AI systems integrated into their critical functions.
- Obligation
- Comprehensive mapping of dependencies, documented exit strategies, mandatory contractual clauses (DORA Art. 28-30); direct supervision of critical TIC providers by European authorities (Art. 31). Qualification of high-risk AI systems embedded (AI Act Art. 6, Annex III) with governance, transparency, human oversight obligations.
- Deadline
- DORA fully applicable since 17 January 2025. AI Act: prohibitions from 2 February 2025, GPAI obligations from 2 August 2025, high-risk systems from 2 August 2026.
- Sanction
- National sanctions for financial entities (DORA Art. 50-54); periodic penalty payments up to 1% of average daily worldwide turnover for critical TIC providers (Art. 35); cumulation possible with AI Act fines up to €35M or 7% of global turnover (Art. 99); ESAs supervisory measures and risk of authorisation withdrawal.
Verified sources · Regulation (EU) 2022/2554 (DORA) · Regulation (EU) 2024/1689 (AI Act) · DORA Art. 28-30, 50-54 · AI Act Art. 6, 26, 99 · Annex III §5b