On behalf of Deloitte, we are pleased to provide EBA with a number of detail comments on the EBA draft Guidelines on ICT and security risk management. For your convenience, these comments were provided both as notes in the PDF and also as a consolidated table in XLS format. Several Deloitte practitioners from multiple offices in the Member States have contributed, bringing their viewpoints: from EU regulatory perspective, NIS (banking) perspective and ICT security risk management perspective.
Dan Cimpean