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EBA guidelines

Upstream status: the European Banking Authority guidelines in this pack are being withdrawn in favour of DORA, and the status of each is to be confirmed on the authority's website. Today 7 of 25 requirements checked from evidence (target 3); the other 18 take a provider attestation. The mapping is not yet reviewed.

What it is

EBA is a native, attestation-led pack. It carries one row per section of three EBA guidelines: GL/2019/04 section 3.8 (ICT and security risk, as amended by GL/2025/02), GL/2019/02 (outsourcing) and GL/2020/06 (loan origination). Ids are as published; each row is a one-line description in this project's own words. The guidance text is not reproduced.

Does it apply to you

The pack asks four questions: is the organisation a supervised institution, does it supply one, does it grant or assess credit, and does it provide payment services. A supplier to an institution gets the pack as voluntary. An organisation that is neither is not_applicable. Answers to the credit and payment questions scope individual rows out. Confirm with your adviser.

How rows are decided

Every row reads Unverified until you record an attestation. Seven rows are hybrid: a file the scaffolds create gives supporting evidence next to the attestation. Evidence found gives Met, Partial or Missing. It never lowers a row and never makes an unattested row Met.

Requirements

Requirement Title Evidence class Sources TTL days Review
EBA:GL/2019/04 3.8 Payment service user relationship management organisational attestation: EBA:GL/2019/04 3.8 365 mapping not yet reviewed
EBA:GL/2019/02 Section 3 Outsourcing (Title II, assessment of arrangements) organisational attestation: EBA:GL/2019/02 Section 3 730 mapping not yet reviewed
EBA:GL/2019/02 Section 4 Critical or important functions organisational attestation: EBA:GL/2019/02 Section 4 365 mapping not yet reviewed
EBA:GL/2019/02 Section 5 Sound governance arrangements and third-party risk organisational attestation: EBA:GL/2019/02 Section 5 365 mapping not yet reviewed
EBA:GL/2019/02 Section 6 Sound governance arrangements and outsourcing organisational attestation: EBA:GL/2019/02 Section 6 365 mapping not yet reviewed
EBA:GL/2019/02 Section 7 Outsourcing policy organisational attestation: EBA:GL/2019/02 Section 7 365 mapping not yet reviewed
EBA:GL/2019/02 Section 8 Conflicts of interests organisational attestation: EBA:GL/2019/02 Section 8 365 mapping not yet reviewed
EBA:GL/2019/02 Section 9 Business continuity plans organisational attestation: EBA:GL/2019/02 Section 9 365 mapping not yet reviewed
EBA:GL/2019/02 Section 10 Internal audit function organisational attestation: EBA:GL/2019/02 Section 10 365 mapping not yet reviewed
EBA:GL/2019/02 Section 11 Documentation requirements hybrid attestation: EBA:GL/2019/02 Section 11; artifact: vendor_register (corroborating) 365 mapping not yet reviewed
EBA:GL/2019/02 Section 12.1 Supervisory conditions for outsourcing organisational attestation: EBA:GL/2019/02 Section 12.1 365 mapping not yet reviewed
EBA:GL/2019/02 Section 12.2 Risk assessment of outsourcing arrangements organisational attestation: EBA:GL/2019/02 Section 12.2 365 mapping not yet reviewed
EBA:GL/2019/02 Section 12.3 Due diligence organisational attestation: EBA:GL/2019/02 Section 12.3 365 mapping not yet reviewed
EBA:GL/2019/02 Section 13 Contractual phase hybrid attestation: EBA:GL/2019/02 Section 13; artifact: contract_checklist (corroborating) 365 mapping not yet reviewed
EBA:GL/2019/02 Section 13.1 Sub-outsourcing of critical or important functions organisational attestation: EBA:GL/2019/02 Section 13.1 365 mapping not yet reviewed
EBA:GL/2019/02 Section 13.2 Security of data and systems organisational attestation: EBA:GL/2019/02 Section 13.2 365 mapping not yet reviewed
EBA:GL/2019/02 Section 13.3 Access, information and audit rights hybrid attestation: EBA:GL/2019/02 Section 13.3; artifact: contract_checklist (corroborating) 365 mapping not yet reviewed
EBA:GL/2019/02 Section 13.4 Termination rights hybrid attestation: EBA:GL/2019/02 Section 13.4; artifact: contract_checklist (corroborating) 365 mapping not yet reviewed
EBA:GL/2019/02 Section 14 Oversight of outsourced functions organisational attestation: EBA:GL/2019/02 Section 14 365 mapping not yet reviewed
EBA:GL/2019/02 Section 15 Exit strategies hybrid attestation: EBA:GL/2019/02 Section 15; artifact: exit_plan (corroborating) 365 mapping not yet reviewed
EBA:GL/2020/06 4.3 Credit risk policies and procedures organisational attestation: EBA:GL/2020/06 4.3 365 mapping not yet reviewed
EBA:GL/2020/06 4.3.3 Technology-enabled innovation for credit granting organisational attestation: EBA:GL/2020/06 4.3.3 365 mapping not yet reviewed
EBA:GL/2020/06 4.3.4 Models for creditworthiness assessment and credit decision-making hybrid attestation: EBA:GL/2020/06 4.3.4; artifact: model_card (corroborating); evaluator: EVAL_BIAS_FAIRNESS_V1 90 mapping not yet reviewed
EBA:GL/2020/06 4.3.7 Data infrastructure hybrid attestation: EBA:GL/2020/06 4.3.7; artifact: data_provenance_sheet (corroborating) 365 mapping not yet reviewed
EBA:GL/2020/06 5.1 Information and documentation organisational attestation: EBA:GL/2020/06 5.1 365 mapping not yet reviewed

Scaffolds

opencomplai scaffold can create an outsourcing register at docs/vendor-register.md, shared with the third-party pack. Fill it in; the vendor register probe then finds it.

Timeline

Both entries are mapping not yet reviewed, have no application date and are low confidence.

  • eba.gl_2019_04_sections_withdrawn: sections 3.1 to 3.7 of GL/2019/04 are reported as deleted upstream since DORA applies. Only section 3.8 stays in this pack. Mapping not yet reviewed.
  • eba.gl_2019_02_repeal_pending: repeal of the GL/2019/02 outsourcing guideline is reported as pending. It covers the GL/2019/02 rows in this pack. Mapping not yet reviewed.

Gate in CI

Bash
opencomplai check --target EBA --gate EBA --gate-fail-on missing --repo-root .

The gate exits 1 when a requirement it lists is Missing.

What stays attested and why

18 rows are organisational: they describe governance, contracts or decisions that leave no file in a repository. Only a person can vouch for them, so each row states why it takes an attestation. The machine share is a low 7 of 25 because the guidelines are mostly outsourcing governance; this is shown as it is.

Review status

Every row and both timeline entries carry mapping not yet reviewed, at low confidence, and are flagged for founder review. No flag is cleared.

Disclaimer

Not an audit, certification or legal assessment. A result says what evidence was found, not that an institution meets any guideline.