FESE believes that the focus of the NIS Directive review should be to harmonise the existing diverging frameworks at EU / Member States level and to avoid further fragmentation. Actors in the financial sector, including highly regulated ones, should be able to use new technologies without unproportionate burden. Proportional standardised requirements would improve the overall resilience. Nevertheless, where NCAs can supervise, this should be encouraged due to their knowledge of local markets.
Finally, FESE would caution against overly prescriptive measures which would rapidly be outdated due to technological evolution. Instead, we would advocate for solutions that ensure the necessary flexibility and adhere to the principle of “same business, same risk, same rules”.