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On 31 January 2020, the European Insurance and Occupational Pensions Authority ("EIOPA") released guidelines on outsourcing to cloud service providers ("the EIOPA Guidelines"). The EIOPA Guidelines aim to provide guidance to insurance and reinsurance undertakings as well as to competent national supervisory authorities on how the regulatory framework for outsourcing under the Solvency II regime(1) should apply in the case of outsourcing to cloud service providers.
The EIOPA Guidelines have two overarching goals: (a) to provide clarification and transparency to market participants in order to avoid potential regulatory arbitrage and (b) to foster supervisory convergence regarding the expectations and processes applicable to cloud outsourcing...
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