With reference to the EBA consultation paper Draft Guidelines on Outsourcing arrangements", as part of Title 2, section 11 "Definitions", a critical or important function is defined as an "outsourcing of a function which is considered as critical or important including any operational tasks performed by the internal control functions ". In this regard, the Studio Annunzata & Conso requires clarification of what is meant by "any operational tasks performed by the internal control functions"."

With reference to the EBA consultation paper Draft Guidelines on Outsourcing arrangements", as part of Title 3, section 6 "Business continuity plans", it is specified that "Where the failure of the service provider to provide the critical or important function would lead to strict business disruption, institutions and payment institutions should involve the service provider in its business continuity planning (...) ". In this regard, the Studio Annunziata & Conso requires clarification of how the involvement of the service provider must be implemented in the business continuity planning."