Greatest possible Efficiency and Flexibility for Companies

Commerzbank promotes standardisation of specific cloud requirements of the financial industry

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Monika Njegac-Wagner

Commerzbank

12/03/2024

Logo of the European Cloud User Coalition (ECUC)
© European Cloud User Coalition

As an innovative and modern bank, Commerzbank has been using cloud technology for years and can therefore operate efficiently and flexibly.

For users, there are a number of benefits to the application of public cloud technology: It offers high availability, is scalable in terms of resources, and provides automation and pre-built services. This leads to faster product development and cost savings and thus facilitates innovation. It also offers very high security standards.

As financial institutions operate with sensitive data and the financial provision in Europe needs to be ensured, they are subject to more restrictive regulations than other sectors. Commerzbank has always met these requirements. However, these currently have to be agreed between the respective cloud provider and financial institution by means of complex negotiations and individual solutions, which leads to high costs on both sides.

ECUC – a powerful voice for the financial industry

In 2021, Commerzbank initiated the founding of the European Cloud User Coalition (ECUC) with 12 other institutions. Through ECUC, the financial industry is now addressing its needs for cloud technologies with one voice. The coalition now has 32 members, and they have set themselves the goal of promoting the secure, standardised, and effective use of cloud services in dialogue with vendors, regulators, and standards-setting organisations.

To this end, the coalition has published a Position Paper listing the most important requirements related to the fields of data protection, portability, security, regulation, and contract arrangements. The accompanying ECUC Checklist, a document covering around 200 questions, helps financial institutions and cloud providers alike to create transparency for the use of cloud services, standardise contracts, and thus increase outsourcing efficiencies. It also publishes positions on the European Union’s Digital Operational Resilience Act (DORA), which aims to strengthen the information and communication security of financial companies in Europe.

ECUC provides feedback on draft EU regulations

In an ever-changing regulatory environment, the coalition relies on active participation in public consultations. Supported by all members, ECUC provided feedback to the responsible European Supervisory Authorities on drafts of the Digital Operational Resilience Act, which serves as the basis for EU regulations for the European Commission.

In addition, the coalition participates in a European Commission working group, to which it contributes its practical experience in implementing public cloud services. Most recently, ECUC has provided feedback on the draft of the European Central Bank (ECB) Guide, which sets out the expectations of supervision regarding cloud use for future audits of European financial institutions.

ECUC sets standards for specific requirements of the financial industry

ECUC is committed to working with the Cloud Security Alliance (CSA), a global leader in standardising and certifying clouds and cloud security. Auditors use the CSA´s catalogue of requirements for their audits. Up to now, the specific requirements of the European financial industry have not been explicitly included. To change this, ECUC has been cooperating with CSA since 2023. Recently, an extension was published specifically for the financial sector, for which ECUC has provided relevant content.

In this video interview, Bernhard Spalt (Chief Risk Officer), Oliver Dörler (Divisional Board Member Big Data & Advanced Analytics) and Monika Njegac-Wagner (Head of ECUC Workstream and ECUC Moderator) from Commerzbank answer questions on the topic.

Kathrin Jones is sitting in a panel discussion with Oliver Dörler, Bernhard Spalt and Monika Njegac-Wagner.
Bernhard Spalt (Chief Risk Officer, 2.f.r.), Oliver Dörler (Divisional Board Member Big Data & Advanced Analytics, 2.f.l.) and Monika Njegac-Wagner (Head of ECUC Workstream and ECUC Moderator, right) answer questions from the presenter, Kathrin Jones of Corporate Communications, about the topic ECUC.© Commerzbank
Portait Bernhard Spalt
© Commerzbank AG

Bernhard Spalt

Chief Risk Officer

Bernhard Spalt studied law at the University of Vienna with a focus on European law. He was Head of Group Risk Management at Erste Group Bank, later on Chief Risk Officer in Austria, Hungary, the Czech Republic, Slovenia, and Romania, and Chief Executive Officer from 2020 to 2022. On 1 January 2024, he took on the position of Chief Risk Officer of Commerzbank, with responsibility for Big Data & Advanced Analytics, Group Validation, Group Compliance, Group Credit Risk Management, Group Cyber Risk & Information Security, and Group Risk Control.

Portrait Oliver Dörler
© Commerzbank AG

Oliver Dörler

Division Head of Big Data & Advanced Analytics

Oliver Dörler studied computer science with a focus on artificial intelligence and data management in Stuttgart. After working at Deutsche Bank and Deloitte, he joined Commerzbank in 2019. As Cluster Lead Big Data, he was responsible for the technical and data foundation for Big Data & Advanced Analytics before taking on his current position on 1 May 2024.

Portrait Monika Njegac-Wagner
© Commerzbank AG

Monika Njegac-Wagner

Head of ECUC Workstream and ECUC Moderator

After studying economics, Monika Njegac-Wagner started working in Commerzbank´s Corporate Customer segment of Commerzbank in 2001. After positions in rating, sales management, project management and regulatory, she has been Head of an ECUC workstream since 2021. She is also an elected moderator of ECUC.

Establishment of the European Cloud User Coalition (ECUC)

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Foundation

01/2021: Commerzbank initiates the founding of ECUC with 12 other financial institutions. The aim is to promote an efficient and compliant use of public clouds in the financial industry.

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Position Paper 1.0

05/2021: ECUC published first official position paper with common requirements of the financial industry.

Checklist 1.0

09/2022: ECUC members agree on a checklist with 200 questions on the review of data protection, portability, security, regulatory and contract arrangements.

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DORA consultation

06/2023 to 03/2024: After feedback from, among others, the ECUC, the European Supervisory Authorities (ESAs) are revising drafts for the European Commission as a basis for EU regulations.

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Cooperation

02/2024: On the initiative of ECUC the Cloud Security Alliance (CSA) adds global security standards specifically for the European financial industry.

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ECB Guide

07/2024: The ECUC, which now has 32 members, gives feedback on the ECB Guide on cloud outsourcing. It sets out detailed expectations of the ECB in the audit of financial institutions.