The World Federation of Exchanges broadly welcomes ESMA's proposals and recognises the value of increasing the focus on the resilience of financial services and their third-party service providers, especially in light of the pandemic and its consequences. The WFE’s members work closely with their cloud service providers to enhance their resilience and further protect their IT infrastructure. To that end, the WFE membership understand – and have implemented measures aimed at addressing – the importance of ensuring that the right controls and safeguards are in place around not only critical outsourcing but all forms of outsourcing.

The Draft Guidance is helpful in the levelling-up of standards across the ecosystem of financial services’ operations which is vital to achieving operational resilience objectives. The WFE has also made considered suggestions concerning how best to implement the proposals in its response.

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