Erhvervsudvalget 2019-20
ERU Alm.del Bilag 219
Offentligt
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s
MINISTER FOR INDUSTRY,
Valdis Dombrovskis
Executive Vice-President for An Economy that Works for People and
Commissioner for Financial Services, Financial Stability and Capital
Markets Union
European Commission
BUSINESS AND FINANCIAL
AFFAIRS
MINISTRY OF INDUSTRY,
Dear Executive Vice-President Valdis Dombrovskis
The Danish government welcomes the opportunity to respond to the Eu-
ropean Commission’s consultation
regarding digital resilience and se-
curity in the EU financial sector.
Cybersecurity is a high priority for the Danish government and it con-
stitutes an important issue both for the Danish and for the wider Euro-
pean society.
The European financial sector is evolving ever more rapidly, ever more
advanced information and communication technology (ICT) systems
and solutions is applied. All this amplify the need to ensure digital resil-
ience in the European financial sector. This in turn requires enhanced
regulatory approaches and supervisory practices.
We agree that more steps are needed to safeguard both financial institu-
tions and our citizens. This is vital for ensuring not just financial stability
in the EU but also continued and well-deserved trust in the financial
sector from citizens, business and authorities.
Shared systems and information
In Denmark, we have set out a number of supporting initiatives to bolster
our defenses and increase cyber resilience. These include amongst oth-
ers:
A cyber strategy for our financial sector
A forum for exchange of information between our financial sec-
tor and the central bank of Denmark (Danmarks Nationalbank)
on operational resilience
A common test framework, TIBER-DK,
based on the ECB’s
TIBER framework
BUSINESS AND FINANCIAL
AFFAIRS
Slotsholmsgade 10-12
1216 Copenhagen K
Denmark
Tlf.
+45 33 92 33 50
Fax.
+45 33 12 37 78
CVR-nr. 10092485
EAN nr. 5798000026001
[email protected]
www.em.dk
As our initiatives indicate, we find it imperative that efficient platforms
and reporting is part of a new framework, in order to assist in the sharing
of information, in particular regarding cyber incidents.
Shared systems for exchanging best practices, a common taxonomy as
well as an established mechanism for reporting on incidents are all key
 ERU, Alm.del - 2019-20 - Bilag 219: Notat samt høringssvar om svar på EU-Kommissionens offentlige høring om modstandsdygtighed overfor cyberangreb i den finansielle sektor, fra erhvervsministeren
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elements in improving robustness, preparedness and resilience amongst
financial actors.
However, such a framework must be fit-for-purpose. The purpose must
be to have efficient and smooth systems that are neither overly expen-
sive nor impractical for stakeholders to participate in.
Information sharing is key in improving the resilience in the financial
sector. The EU has an important role in facilitating efficient cross-bor-
der/sectoral cooperation between institutions to promote voluntary in-
formation sharing.
Critical third party providers
The consultation document identifies a diversity of issues and signifi-
cant risks that arise from the increasing reliance on critical third party
providers in the financial sector. This is also part of the findings in the
Joint Advice from the ESAs on the need for legislative improvements
relating to ICT risk management requirements.
We agree that these developments in relation to third party providers
should be addressed by an adequate strengthening of the legal frame-
work in order to mitigate new risks arising from both fragmentation in
jurisdictions and concentration of providers.
We are looking very much forward to assisting you and the Commission
services in formulating a new framework in order to improve our com-
mon resilience in this new and digital era which present exciting oppor-
tunities but also difficult challenges that we need to address together.
Attached you will find our specific replies to the consultation document.
As always, I remain at your disposal should you have any questions or
comments.
Yours sincerely,
Simon Kollerup