Solutions

Transparent sub-outsourcings

Leno enables efficient and compliant documentation and monitoring of entire outsourcing chains and ICT subcontracting arrangements

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Why subcontracting is a challenge

In practice, risks often arise less from the primary service provider and more from its subcontractors.

Lack of oversight

  • Missing complete mapping of primary service providers and subcontractors in line with DORA, EBA Guidelines and MaRisk
  • Unclear allocation to critical or important functions
  • Changes within the supply chain are not systematically captured

Lack of transparency

  • Dependencies between primary service providers and subcontractors are not clearly identifiable
  • Concentration and operational resilience risks remain undetected
  • Responsibilities along the supply chain are unclear

Stringent regulatory requirements

  • Insufficient traceability of risk assessments and approval decisions
  • Documentation is not audit-ready or not up to date
  • Increased risk of findings by supervisory authorities and internal audit
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How Leno manages subcontracting and ICT sub-outsourcing

Leno enables financial institutions to centrally and systematically manage subcontracting arrangements throughout their entire lifecycle.

Completely recording of all subcontractors

  • Mapping of Primary Service Providers → Subcontractor → Additional Outsourcing Layers
  • Allocation to critical and important functions
  • Complete change history for all subcontracting arrangements

Integrated risk assessment for subcontractors

  • Assessment of:
    • Criticality
    • Concentration risks
    • Information security risks
    • Data Protection
    • Operational Outage and Dependency Scenarios
  • Linked with existing ICT risk assessments.

Continuous monitoring and updates

  • Regular, audit-proof updates of risk assessments
  • Automated Transfer to the Outsourcing Register and the Information Register
  • Tracking of changes across the ICT supply chain
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Further relocations are documented with basic functions, static workflows or individual solutions — without complete transparency across multi-stage supply chains.

Why Leno manages relocations and ICT services more effectively

Other Tools

Basic functions, static workflows and separate individual solutions.
Full compliance, configurable, integrated and AI-supported.
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Monitoring and documentation
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Subcontracting is documented but not actively managed or monitored.
Structured management of subcontracting including risk assessment, approval and continuous monitoring.
Transparency across ICT supply chains
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Limited visibility into subcontractors, often only the first outsourcing layer.
Full transparency across multi-layer ICT supply chains, including third and fourth-party providers.
Compliance & regulation (DORA, EBA, MaRisk)
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Generic compliance features without a specific focus on subcontracting
Targeted management of subcontracting aligned with DORA, EBA Guidelines and MaRisk.
Audit & audit ability
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High manual effort to prepare audit-relevant evidence
Audit-ready documentation of all decisions at the push of a button.
Responsiveness to changes
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Often not available
Continuous monitoring of subcontracting arrangements with clear ownership and up-to-date information.
Flexibilität
Andere Tools sind statisch oder nur mit Programmierung
Leno ist konfigurierbar ohne Code
Modul-Integration
Andere Tools bilden getrennte Einzellösungen
Leno ist eine All-in-One-Plattform, nahtlos verknüpft
Startgeschwindigkeit
Andere Tools erfodern lange Implementierung
Leno ist sofort einsatzbereit mit Templates
KI-Funktionen
In anderen Tools oft nicht vorhanden
Leno verfügt über integrierte KI für Analyse & Automatisierung

Key Questions on Sub-Outsourcings and ICT Subcontracting

What you should know about sub-outsourcings and ICT subcontracting
When is there a further outsourcing or ICT subcontracting arrangement?

A further outsourcing occurs when a service provider outsources all or part of the services it provides to a financial institution to a third party. This applies regardless of whether the outsourcing is permanent or temporary. If the outsourced services involve information and communication technology (ICT), this is referred to as an ICT subcontracting arrangement.

Do all subcontractors need to be approved?

Not every subcontractor needs formal approval - the key factor is risk relevance. Subcontractors providing services related to critical or important functions or significantly affecting ICT risks must be assessed and approved in advance. For non-critical services, simplified documentation may be sufficient.

How detailed must the documentation be?

The documentation must be detailed enough to ensure that risks from further outsourcing are fully traceable and manageable. As long as a further outsourcing arrangement can generate a risk relevant to the institution, the assessment, decision basis, approval, and monitoring must be documented. Supervisors and auditors must be able to see at any time which further outsourcing arrangements exist, which risks have been assessed, and how they are being managed.

How does Leno support audits?

Leno provides all audit-relevant information on further outsourcing centrally, up-to-date, and in a traceable manner. Risk analyses, approvals, decisions, and changes in the ICT supply chain are documented in a structured way and can be accessed at any time in an audit-proof manner. This allows institutions to respond quickly and consistently to internal audits, external auditors, and supervisory authorities without manually compiling information.

Is a contract with the main service provider sufficient?

From a regulatory perspective, financial institutions are also expected to have transparency and control over subcontractors that are used as part of onward transfers. It is not only the contract that is decisive, but the actual monitoring of the entire ICT supply chain. The institution remains fully responsible even with subcontractors and must be able to assess risks, document approvals and understand changes.

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