3.3.1 Cross-sectoral
21. The TLPT methodology and process set out in the proposed RTS does not include any sector-specific or entity-specific requirements (i.e. sector-agnostic and entity-agnostic requirements). This is in line with the sector agnostic approach taken by the TIBER-EU framework which has in the past been used for many different kinds of financial entities or even entities outside of the financial sector.
Q1. Do you agree with this cross-sectoral approach? If not, please provide detailed justifications and alternative wording as needed.
3.3.2 Proportionality
22. The proposed draft RTS includes the proportionality principle in the criteria that are used to identify financial entities required to perform TLPT. Only financial entities that carry a certain degree of systemic importance and are mature enough from an ICT perspective are required to perform a TLPT (as described in the following paragraphs).
23. Since all financial entities that are required to perform TLPT m
…