“Cloud computing is driving both the digital transformation of banks and the EU Digital Single Market. We need to create a safe and clear regulatory environment so that both banks and supervisors can do their job well.”

Wim Mijs

“Understanding the risks of cloud computing is essential to unlock its potential. European banks use technology widely to maintain resilience, boost innovation and support their clients, especially at times when digital infrastructure is necessary to respond to high usage at all levels…

…The Cloud Banking Forum is a unique example of cross-industry cooperation that reflects the ambitions of the digital strategy of EBF and our wider banking community.”

“ The success of our first Cloud Banking conference and the launch of the EBF Cloud Banking Forum demonstrates that there is a willingness to innovate and a thirst for clear rules in cloud banking.”

Wim Mijs

“In a future world of minimum retained IT with a high level of agility, variable costing, improved time-to-market and broad usage of AI and other exponential technologies, cloud will play a very important role. But before banks can reap the benefits from a multi-cloud environment, the security, operational, legal and compliance requirements need to be crystal clear, allowing for a cloud approach which is integrated, economically viable and at scale…


…To achieve this, we need to collaborate with cloud service providers and regulators. The Cloud Banking Forum is the platform for these types of discussions, highlighting the importance of cloud computing as the undeniable core technology for banks and supervisors.”



EBF position on the Commission’s DORA proposal (2020): Key points

The adoption of innovative technology by European banks requires a balance between a reliable and consistent framework of financial regulation and flexibility to adapt to changing business models. The inherently cross-border nature of digital service solutions needs to be addressed by banks, regulators, and digital service providers on common ground, looking for the secure facilitation of financial service innovation across Europe. An appropriate and harmonized pan-European legal framework is key to facilitate the adoption of innovative technology.

Consequently, the EBF welcomes the European Commission’s aim to enhance operational resilience in Europe. The financial industry’s own considerations will benefit from more harmonized ICT-related rules at the European level, aligned with the existing supervisory framework today. Detrimental fragmentation of the regulatory framework should be avoided, addressing risks consistently and proportionately across European jurisdictions without hampering the financial industry’s ability to apply innovative services.

With this position paper, the EBF addresses the proposal for a Regulation on digital operational resilience for the financial sector, as published by the Commission in September 2020. Full position available HERE


Digitalisation of services and globalisation have led to significant changes in methods of data collection, access and use. Especially in the banking industry.
This has recently contributed to an increased interest in cloud computing as a means to support the digitalisation of financial services. It is not only about storing data in the cloud but outsourcing your computing power meeting the business needs. By doing so, cloud-based infrastructures can be a driving force behind better software performance, data analytics, and emerging technologies such as distributed ledgers and artificial intelligence.

However, banks have been slower in their uptake of cloud services when compared to other industries due to the strict regulatory environment where banks operate in. Correspondingly, legal and regulatory constraints limit cloud adoption in banking, but also the lack of harmonised regulatory approaches across different jurisdictions and between regulators contributes to a high threshold. Moreover, using, managing and storing customer information faces higher compliance risks, especially in an international environment and in the light of data and security guidelines (e.g. GDPR).

The contractual negotiations between banks and cloud service providers (CSPs) are facing significant frictions.

Cloud computing in many forms (private, public, hybrid). Public cloud solutions let service providers make resources like apps and storage available via an accessible network where multiple clients can share the same resources.  A hybrid cloud is an integrated cloud service utilising both private and public clouds to perform distinct functions within the same organisation.
These forms can be deployed through different service models.

Moving beyond legacy infrastructure, the journey to cloud-driven organisation knows several phases. As banks are keen to use the innovative potential of cloud technology they take into account risk management and organisational structure.


The EBF Cloud Banking Forum is a unique attempt to create a dialogue between relevant authorities, cloud service providers (CSPs) and banks aimed to enable the creation of a harmonised supervisory approach towards cloud computing and to support the rapid adoption of public/hybrid cloud solutions in the banking sector.
In its initial work streams, the EBF Cloud Banking Forum created three technical papers, reflecting important aspects for cloud adoption by European banks. By the support of a harmonized regulatory framework through suggestion of voluntary best practices and provision of educational background, Cloud Service Providers and European banks are looking to avoid detrimental fragmentation for cloud computing across the EU. To that end, the papers reflect on special features of cloud use by financial institutions and address requirements under the EBA Guidelines on outsourcing arrangement from a cloud-specific perspective.

Cloud banking summary note

After an initial engagement with its EU observers in the past, the Cloud Banking Forum is looking forward to discussing the proposed papers with the observers in detail. Insights gained from these conversations will help to shape the products of the Forum further, updating them in the face of a fast-developing cloud environment that continues to evolve.



The second edition of the “Cloud in Financial Services” report re-examines the research conducted by Reply with financial institution, and addresses the unique challenges facing financial institutions in the EU, Switzerland, and UK.

The latest report on cloud adoption in the financial services sector highlights significant changes since the 2021 edition. Financial institutions are now more discerning in their approach to cloud technology, emphasising hybrid and multi-cloud environments for a strategic use. While asset management leads in adoption, most institutions still use the cloud primarily for non-critical applications. The perception of cloud benefits has evolved, shifting from cost reduction to system resilience as the top priority. Challenges such as regulatory compliance and data sovereignty persist, but security concerns have diminished. This reflects a maturing understanding of cloud technology. The report emphasises the need for a tailored approach, incorporating multi-cloud and hybrid cloud strategies, and a strategic understanding of cloud technology to maximise its benefits and navigate regulatory complexities.

Read the full report here


According to the European Commission, cloud computing is developing fast. Estimates indicate that these developments could lead to the growth of the European cloud market from €9.5bn in 2013 to €44.8bn by 2020, i.e. almost five times the market size in 2013. Within the Digital Single Market Strategy for Europe, the key role of cloud computing is established through the European Cloud Initiative and through the initiative on Building a European Data Economy.

The European Cloud Initiative focuses is complemented by other initiatives under the Digital Single Market (DSM) to promote the development and uptake of cloud services, focusing on certification, switching of cloud service providers and security. These actions incorporate input from the European Cloud Partnership (ECP) and the Cloud Select Industry Group (C-SIG).

The EBF works together with the Commission on several topics and projects. The Commission is also an observing member of the EBF Cloud Banking Forum.

Digital Single Market and Cloud Computing

16 April 2018: Cloud stakeholder working groups start their work on cloud switching and cloud security certification

10 June 2019 – European Trusted Cloud Service Provider Working Group (CSP CERT): Final Public-Private recommendation for a European Security Certification Scheme



Competing in Digital Finance: New rules for a new market

Thursday, 4 November 2021



The second Digital Thursday 2021 focused on the evolving competition landscape in digital financial services and the challenges this poses to the ongoing digital transformation of banking and banks. Access to relevant infrastructure and data, as well as the supervisory framework are key enablers to innovation. The event discussed the importance of ensuring fair competition among participants in the digital market and will offer exchange of views on some of the key policy debates such as the Digital Markets Act, access to and sharing of data, and the role Digital ID can play in this shifting landscape.


Evolution in financial services: tomorrow’s technology in today’s framework?

Thursday, 12 November 2020



Financial services experience an unprecedented digital transformation, with the technology-driven evolution of products, services, and available infrastructure. Innovation offers the exponential potential to serve customers and advance business operations. At the same time, European banks approach such innovation with a commitment to existing regulatory responsibilities and a commitment to financial stability in Europe.

The EBF’s Innovation & Cyber Thursday on 12 November 2020 shined the light on the importance of an appropriate framework for banks to grasp the innovative potential offered by technology while abiding by today’s rules. Where both come together, the financial industry requires options to safely advance innovative solutions at scale. Digital operational resilience lies at the heart of these solutions, requiring 360⁰ attention to changing roles of different parties involved in the ICT landscape. The event looked at European advancement of regulation for digital operational resilience, established and aspired partnerships to implement innovative technology and the global perspective for safeguarding innovation in finance.


European banks want to adopt innovative cloud technology, to allow them to – operate in a fast-developing digital environment, to serve customers and to adapt their business in order to strive for the EU’s digital leadership role.

In December 2017, the European Banking Federation launched the EBF Cloud Banking Forum, a policy hub on cloud computing for European banks and Cloud Service Providers to support a harmonised supervisory approach towards cloud computing. This will facilitate the adoption of public/hybrid cloud computing by European banks on a larger scale.

The 2nd EBF Cloud Banking Conference will present the results of this cooperation and allow supervisory authorities, representatives of EU institutions, Cloud Service Providers and European banks to engage on the future of cloud adoption, from both a European and global perspective. The event will also prove valuable in the context of the implementation of the European Banking Authority’s Guidelines on outsourcing arrangements.


For information on the 2017 edition please visit this page