A timely reminder that the EBA guidelines come in to force on 30 September 2019. Outsourcing contracts entered into, reviewed or amended on this date onwards by financial institutions whose activities fall within scope must comply with the guidelines. 

In addition, by 31 December 2021, all entities within scope must ensure their existing outsourcing contracts have been updated and reviewed to ensure compliance with the guidelines.

Experience says that this type of review and update exercise takes much longer than expected. A good place to start now is to work out whether each entity's assessments as to critical and important functions are still in line with the updated guidelines. That will at least give financial institutions an indication as to how many contracts are in scope to be reviewed and updated.