DIGITALEUROPE’s Response to the European Commission’s Consultation on DORA’s Delegated Acts on Criticality Designation Criteria and on Oversight Fees

DIGITALEUROPE appreciates the opportunity to provide comments to the European Commission on the draft delegated acts under DORA mandate. We welcome the Commission’s sensible approach, advancing the ESA guidance delivered in the Joint Report on 29 September. The draft delegated acts show a welcome focus on proportionality in many aspects raised by industry stakeholders under the ESA consultation in 2023. We would like to offer the following comments to further strengthen the principle of proportionality and to constructively support additional legal clarity and certainty.