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EBA Q&A 2025_7367 — Q&A — Correct classification of services related [Rejected question]

Financial servicesLevel 3Q&ADORARejectedOfficial source

Correct classification of services related to the 'reselling' of software provided in SaaS mode

Question

With reference to the correct identification of the type of ICT services, taking into account the types contained in ANNEX III of Regulation (EU) 2024/2956, how should services related to the 'reselling' of software provided in SaaS mode be classified?

Background

The doubt arises from the fact that access to software provided in SaaS mode (e.g., Microsoft 365) often occurs through a reseller and not with direct access to the owner of the software and the underlying infrastructure. The identifier S13 obviously excludes this mode of software delivery, and therefore the only alternative remains the identifier S19. However, the latter seems to refer to SaaS services provided directly by the owner.


Answer

This question has been rejected because the matter it refers to has been answered in No. 107 of the Frequently Asked Questions on the Register of information.


Source: EBA original document