EBA/GL/2019/02

What the authority establishes

Applicable EBA/GL/2019/02 guidance addresses outsourcing governance, criticality, due diligence, contracts, monitoring, subcontracting, and exit. The EBA published final replacement guidance for non-ICT third-party services on September 18, 2026; it is not yet applicable and will repeal the 2019 version only once applicable.

Financial entities need to preserve the applicable 2019 outsourcing baseline while mapping the final, pending non-ICT third-party-risk framework by arrangement, criticality, authority, and effective date. Publication and translation are not the application trigger.

The record is written for operational interpretation, not legal advice. Applicability depends on entity type, jurisdiction, relationship, service, data, criticality, contractual commitments, and later authority guidance.

Who should read it

The primary audiences named in this review are EU banking and financial-institution outsourcing teams, operational-risk and resilience leaders, procurement, legal, compliance, and internal-audit teams, payment and electronic-money institutions, service providers supporting critical or important functions. Those roles may divide responsibility differently, but the operating record should still show scope, accountable ownership, evidence, review, exceptions, and the final decision.

Third-party lifecycle implications

Governance

Teams should determine what this authority expects at the governance stage, which function owns the judgment, what evidence must be retained, and what later change would reopen the record.

Pre-Outsourcing Analysis

Teams should determine what this authority expects at the pre-outsourcing analysis stage, which function owns the judgment, what evidence must be retained, and what later change would reopen the record.

Due Diligence

Teams should determine what this authority expects at the due diligence stage, which function owns the judgment, what evidence must be retained, and what later change would reopen the record.

Contracting

Teams should determine what this authority expects at the contracting stage, which function owns the judgment, what evidence must be retained, and what later change would reopen the record.

Register Maintenance

Teams should determine what this authority expects at the register maintenance stage, which function owns the judgment, what evidence must be retained, and what later change would reopen the record.

Ongoing Monitoring

Teams should determine what this authority expects at the ongoing monitoring stage, which function owns the judgment, what evidence must be retained, and what later change would reopen the record.

Subcontractor Oversight

Teams should determine what this authority expects at the subcontractor oversight stage, which function owns the judgment, what evidence must be retained, and what later change would reopen the record.

Exit Strategy

Teams should determine what this authority expects at the exit strategy stage, which function owns the judgment, what evidence must be retained, and what later change would reopen the record.

Capabilities that may support the work

These links identify relevant operating capabilities; they do not state that any product creates compliance.

Intake And Inventory

establishing an accountable record of relationships, products, owners, and critical services. Buyers should test the workflow against their own scope and evidence requirements.

Inherent Risk Tiering

using relationship context to determine proportional diligence and review. Buyers should test the workflow against their own scope and evidence requirements.

Due Diligence And Assessments

collecting and reviewing evidence before and during a relationship. Buyers should test the workflow against their own scope and evidence requirements.

Evidence Collection

preserving source material, responses, and reviewer context. Buyers should test the workflow against their own scope and evidence requirements.

Continuous Monitoring

bringing material external and internal change into an owned response workflow. Buyers should test the workflow against their own scope and evidence requirements.

Issue Remediation

assigning findings, deadlines, exceptions, and closure evidence. Buyers should test the workflow against their own scope and evidence requirements.

Fourth-Party Visibility

identifying and explaining important downstream dependencies. Buyers should test the workflow against their own scope and evidence requirements.

Regulatory Mapping

connecting program records to obligations and examination needs. Buyers should test the workflow against their own scope and evidence requirements.

Reporting

turning program activity into operator, executive, and board-ready information. Buyers should test the workflow against their own scope and evidence requirements.

Offboarding

closing access, data, evidence, and residual obligations when a relationship ends. Buyers should test the workflow against their own scope and evidence requirements.

What software cannot decide

Software can structure records, route work, preserve evidence, surface change, and support reporting. It cannot determine legal applicability, set risk appetite, negotiate accountable contract terms, validate every external claim, accept residual risk, or make management responsible for an outcome. Those remain organizational decisions.

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