Regulatory AlertsDOC-2021-05 Guidelines on Outsourcing to Cloud Service Providers
The AMF issued position DOC-2021-05 to integrate the updated ESMA Guidelines on outsourcing to cloud service providers, which became applicable on September 30, 2025. These guidelines apply to competent authorities, AIFM depositaries under Article 21 of the AIFMD, and UCITS depositaries under Article 23 of the UCITS Directive, specifically excluding financial entities subject to the DORA regulation. This document supersedes the AMF's previous July 6, 2021 declaration of compliance with the earlier version of the ESMA guidelines.
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III - Service Providers III. 1 - Investment Service Providers III. 1.3. Rules of Good Conduct Doctrine Compliance
Guidelines on Outsourcing to Cloud Service Providers
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Applicable from November 28, 2025 Position DOC-2021-05
Download Viewed Version Summary This position incorporates the updated ESMA Guidelines on outsourcing to cloud service providers (the "Guidelines"). The Guidelines are applicable from the date of publication by ESMA, which is September 30, 2025.
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The Guidelines apply to competent authorities and i) depositaries of alternative investment funds (AIFs) referred to in Article 21(3)(c) and Article 21(3), third subparagraph, of the AIFMD Directive, when they are not financial entities to which Regulation 2022/2554 on Digital Operational Resilience in the Financial Sector ("DORA Regulation") applies, and ii) depositaries of UCITS referred to in Article 23(2)(c) of the UCITS Directive, when they are not financial entities to which the DORA Regulation applies. The Guidelines are available on the ESMA website at the following addresses:
- In French: https://www.esma.europa.eu/sites/default/files/2025-09/ESMA65-294529287- 4737_Guidelines_on_outsourcing_to_cloud_service_providers_FR.pdf
- In English: https://www.esma.europa.eu/sites/default/files/2025-09/ESMA65-294529287- 4737_Guidelines_on_outsourcing_to_cloud_service_providers.pdf Archives
On July 6, 2021, the AMF declared that it complies with the ESMA Guidelines on outsourcing to cloud service providers. The guidelines are available at the following addresses: In French: https://www.esma.europa.eu/sites/default/files/library/esma_cloud_guidelines_fr.pdf In English: https://www.esma.europa.eu/sites/default/files/library/esma_cloud_guidelines.pdf
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