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  1. Home
  2. Single Rulebook Q&A
  3. 2025_7367 Correct classification of services related to the 'reselling' of software provided in SaaS mode
Question ID
2025_7367
Legal act
Regulation (EU) No 2022/2554 (DORA Reg)
Topic
Register of information (DORA)
Article
Regulation (EU) 2024/2956 - ANNEX III
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Regulation (EU) 2024/2956 - ITS on the register of information
Article/Paragraph
ANNEX III - Type of ICT services
Type of submitter
Individual
Subject matter
Correct classification of services related to the 'reselling' of software provided in SaaS mode
Question

With reference to the correct identification of the type of ICT services, taking into account the types contained in ANNEX III of Regulation (EU) 2024/2956, how should services related to the 'reselling' of software provided in SaaS mode be classified?

Background on the question

The doubt arises from the fact that access to software provided in SaaS mode (e.g., Microsoft 365) often occurs through a reseller and not with direct access to the owner of the software and the underlying infrastructure. The identifier S13 obviously excludes this mode of software delivery, and therefore the only alternative remains the identifier S19. However, the latter seems to refer to SaaS services provided directly by the owner.

Submission date
05/03/2025
Status
Question under review

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