ESMA Q&A 2328 — Q&A — Regulation (EU) 2022/2554 - The Digital Operational [Question Rejected]
Financial servicesLevel 3Q&ADORARejectedOfficial source
Regulation (EU) 2022/2554 - The Digital Operational Resilience Act (DORA)
Question
We have service providers (Market Axess), who classify themselves as DORA-relevant because they offer regulated financial services (ARM and APA). However, they do not see themselves obligated to make contractual adjustments according to Article 30. This is because "financial services" would not fall under the definition of "ICT service" as per Article 3(21) of DORA. Additionally, this requirement would only apply to non-regulated companies. Is this understanding correct?
Source: ESMA original document