It is important that the rules envisaged by DORA are consistent with the existing rules in banking regulation. Otherwise, this would fragment regulatory standards even further and overburden banks that engage in outsourcing arrangements. In my view, we need a sound supervisory architecture balancing third-party oversight and banking supervision.
In a recently conducted survey on payment behaviour in Germany during the coronavirus pandemic, we found out that the share of cash transactions has fallen from 74% to 60% over the last three years.2 Admittedly, it remains to be seen whether the current behaviour also persists in the post-coronavirus period.