Article 32: Structure of the Oversight Framework

Article 32: Structure of the Oversight Framework requirement is an institutional (EU-level) governance provision that creates an “Oversight Forum” to support the Joint Committee and Lead Overseer on ICT third-party risk. For regulated firms, operationalizing it means being ready to engage with the EU oversight structure through clear internal accountability, a regulatory-response workflow, and well-organized evidence for ICT third-party risk decisions. (Regulation (EU) 2022/2554, Article 32)

Key takeaways:

• Treat Article 32 as a “supervisory interface” requirement: you must be able to respond cleanly to cross-sector oversight activity on ICT third-party risk. (Regulation (EU) 2022/2554, Article 32)
• Build traceability from DORA obligations to owners, controls, and evidence artifacts in one place so responses do not fragment across teams. (Regulation (EU) 2022/2554, Article 32)
• Formalize a regulator-request intake, escalation, and remediation workflow with Legal/Compliance sign-off and auditable closure evidence. (Regulation (EU) 2022/2554, Article 32)

Article 32: structure of the oversight framework requirement sits inside DORA’s oversight regime for ICT third-party risk, and it is easy to misread it as “only for regulators.” The text is addressed to the European Supervisory Authorities’ Joint Committee, instructing them to set up an Oversight Forum to support joint positions and common acts on ICT third-party risk across financial sectors. (Regulation (EU) 2022/2554, Article 32)

Why should a CCO or GRC lead care? Because the existence of a formal oversight structure changes how supervisory expectations show up at your firm: inquiries can be more coordinated, information requests can cut across domains (security, procurement, outsourcing, resilience), and remediation follow-up can require consistent evidence across business lines. Your job is to ensure your organization can interact with this oversight environment without improvisation.

This page translates Article 32 into requirement-level implementation guidance you can stand up quickly: who owns what, what workflows must exist, what evidence must be retained, and what auditors and supervisors tend to press on when your ICT third-party risk posture is questioned.

Regulatory text

DORA Article 32(1) requires the Joint Committee, under its ESA founding regulations, to establish the “Oversight Forum” as a sub-committee to support the Joint Committee and the Lead Overseer (referenced in Article 31(1)(b)) on ICT third-party risk across financial sectors. The Oversight Forum prepares draft joint positions and draft common acts in that area. (Regulation (EU) 2022/2554, Article 32)

What the operator must do with this text Even though Article 32 is directed at EU authorities, it creates an operational reality for firms: a structured oversight layer exists above ICT third-party risk, and your supervisory engagements can reflect joint positions/common acts that come out of that structure. Your implementation target is “readiness for structured oversight,” which means:

• you can explain how ICT third-party risk is governed internally;
• you can produce consistent evidence quickly; and
• you can intake and execute oversight-driven requests and remedial actions without losing accountability.

Use Article 32 as the anchor for your oversight-readiness controls: traceability, regulatory-response workflow, and remediation discipline. (Regulation (EU) 2022/2554, Article 32)

Plain-English interpretation (what this requirement is really asking for)

Article 32: structure of the oversight framework requirement establishes that ICT third-party risk oversight is coordinated at EU level through a dedicated forum that supports cross-sector alignment. (Regulation (EU) 2022/2554, Article 32)

For you, the practical interpretation is:

1. Expect standardization pressure. Joint positions/common acts tend to push harmonized expectations. Your third-party risk approach needs to be coherent across entities and business lines.

2. Expect multi-function evidence requests. ICT third-party risk is not only a procurement file. Requests can touch governance, security testing, incident handling, resilience testing, and remediation tracking.

3. Expect “tell me once” consistency. If Security says one thing, Procurement shows another, and Compliance has a third version, you will spend time reconciling. Build a single source of truth.

Who it applies to (entity and operational context)

Direct addressee: the Joint Committee (ESAs) establishes the Oversight Forum. (Regulation (EU) 2022/2554, Article 32)

Operational applicability for regulated entities: any financial entity in scope of DORA that must manage ICT third-party risk should treat Article 32 as a governance context requirement that drives how oversight-related communications, evidence, and remediation must work internally. (Regulation (EU) 2022/2554)

Where this shows up in your operating model

• Third-party risk management (TPRM) / outsourcing governance: critical ICT providers, concentration risk, exit planning, oversight reporting.
• Information security and ICT risk: control expectations for third parties, testing evidence, incident coordination.
• Legal/Compliance: supervisory communications, interpretation consistency, remediation commitments.
• Business owners: accountability for third-party service outcomes and risk acceptance decisions.

What you actually need to do (step-by-step)

1) Build an “Oversight Readiness Register” for ICT third-party risk

Create one register that ties:

• DORA obligations you track (including this Article 32 oversight-readiness objective),
• control owners (role + named team),
• operational controls (what is done, by whom, at what trigger),
• evidence artifacts (where stored, format, retention owner).

This aligns to the practical control: “Map this DORA requirement to concrete ICT controls, accountable owners, and supervisory evidence artifacts in a single register.” (Regulation (EU) 2022/2554, Article 32)

Minimum fields (operator-grade)

Field	What “good” looks like
Obligation statement	One sentence in plain language tied to Article 32 oversight-readiness
Control objective	“We can respond consistently to cross-sector oversight requests on ICT third-party risk”
RACI	Accountable exec, Responsible ops owners, Consulted Legal/Compliance, Informed business
Evidence list	Specific artifacts with system of record
Response SLA	Your internal time-to-acknowledge and time-to-fulfill targets (define internally)
Exceptions	How you document deviations and approvals

2) Implement a regulatory-response workflow (intake → triage → fulfill → close)

Stand up a workflow that handles requests that could plausibly stem from coordinated oversight activity (even if they arrive via your competent authority). Use the recommended control: “Implement a regulatory-response workflow for requests, escalations, and remedial actions with legal/compliance sign-off.” (Regulation (EU) 2022/2554, Article 32)

Workflow design

1. Intake gate (single front door): Compliance (or Regulatory Affairs) logs every request, assigns a unique ID, tags scope (third party, ICT service, business line).
2. Triage: Decide whether it is informational, requires a remediation plan, or requires board/management escalation.
3. Evidence assembly: Pull from the register, not from ad hoc emails.
4. Quality control: Legal/Compliance confirms position consistency and privilege handling.
5. Submission + record: Store what you sent, when, and who approved it.
6. Remediation tracking: If commitments were made, create tracked actions with owners and due dates.

3) Run readiness drills and prove closure discipline

Supervisors care that you can execute under pressure. Use the recommended control: “Run periodic readiness drills and close identified gaps through tracked corrective action plans with validation evidence.” (Regulation (EU) 2022/2554, Article 32)

How to run a drill (practical)

• Pick one critical ICT third party and simulate a request: “Provide your governance, testing evidence, and remediation status for this service.”
• Time-box collection, approvals, and packaging.
• Log friction points (missing artifacts, unclear owners, conflicting narratives).
• Create corrective actions and re-test after closure.

Required evidence and artifacts to retain

Keep evidence that demonstrates governance clarity, repeatability, and fast retrieval:

Governance and accountability

• ICT third-party risk governance charter (or equivalent committee terms of reference)
• RACI for ICT third-party risk decisions and regulatory interactions
• Meeting minutes where third-party risk and escalations are addressed (sanitized as needed)

Traceability and control operation

• Oversight Readiness Register (the mapping of obligations → controls → evidence)
• Evidence index with system-of-record pointers (GRC tool, document repository, ticketing system)

Regulatory-response workflow artifacts

• Request intake log (ID, date, scope, requester, owner)
• Triage decision record (including escalation if applicable)
• Approval records (Compliance/Legal sign-off)
• Submission package and final version control

Remediation and validation

• Corrective action plans (CAPs) with ownership and due dates
• Validation evidence that actions are complete (test results, change tickets, updated procedures)

Where Daydream fits Daydream becomes the “single pane” for mapping DORA obligations to controls, owners, and evidence artifacts, and for managing regulator-request workflows and remediation tracking without chasing email trails. Keep the register and request workflow in the same system so status and evidence stay linked over time.

Common exam/audit questions and hangups

Auditors and supervisors typically probe for operational coherence:

• “Show me your single source of truth for ICT third-party risk obligations and evidence.” They want traceability, not slideware.
• “Who is accountable for responding to oversight-driven requests?” If ownership floats between Security, Procurement, and Compliance, response quality drops.
• “Prove you can close remediation.” Action lists without validation artifacts fail quickly.
• “Explain discrepancies.” If third-party criticality, service inventory, or control coverage differs across teams, expect follow-up.

Hangup to anticipate: teams treat “oversight framework” as abstract regulator mechanics and skip building the response machinery.

Frequent implementation mistakes and how to avoid them

1. Mistake: parking Article 32 in a legal memo only.
   Fix: convert it into an oversight-readiness control objective with owners and evidence in your register. (Regulation (EU) 2022/2554, Article 32)

2. Mistake: evidence lives in too many places with no index.
   Fix: maintain an evidence index with pointers and named custodians. Enforce version control for anything that goes to a supervisor.

3. Mistake: no escalation path for “this request implies remediation.”
   Fix: bake escalation criteria into the triage step (risk acceptance, contract changes, third-party remediation, customer impact).

4. Mistake: CAP closure is declared without validation.
   Fix: require a closure checklist and attach proof (test output, screenshots, change records, approvals).

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for Article 32. Treat the risk as supervisory friction and delayed response risk: inconsistent evidence, unclear ownership, or poor remediation tracking can turn a routine inquiry into deeper scrutiny under the DORA oversight environment. (Regulation (EU) 2022/2554, Article 32)

Practical 30/60/90-day execution plan

First 30 days (Immediate foundation)

• Appoint a single accountable owner for “ICT third-party oversight readiness” (role-based) and confirm backup coverage.
• Stand up the Oversight Readiness Register skeleton: obligations, owners, evidence placeholders. (Regulation (EU) 2022/2554, Article 32)
• Define the regulatory-response workflow and “front door” intake channel; publish it internally. (Regulation (EU) 2022/2554, Article 32)

Days 31–60 (Operationalize and test)

• Populate the register for your most critical ICT third parties first (prioritize those tied to core services).
• Implement Legal/Compliance sign-off checkpoints and version control for outbound submissions.
• Run one readiness drill; capture gaps and create CAPs. (Regulation (EU) 2022/2554, Article 32)

Days 61–90 (Stabilize and prove repeatability)

• Close the highest-risk gaps from the drill and attach validation evidence.
• Run a second drill with a different third party and a different request type (e.g., governance vs. testing vs. remediation status).
• Formalize a cadence for register review and workflow QA (ownership, evidence freshness, open CAPs).

Frequently Asked Questions

Does Article 32 apply directly to my firm, or only to EU authorities?

The text instructs the Joint Committee to establish an Oversight Forum. (Regulation (EU) 2022/2554, Article 32) You operationalize it by preparing for coordinated oversight expectations with clear ownership, evidence traceability, and a regulator-request workflow.

What’s the fastest way to make this real if I have a small compliance team?

Start with a narrow scope: one register, one intake workflow, and one drill focused on your most critical ICT third party. Keep the artifacts lightweight but controlled (IDs, approvals, versioning).

What evidence will make a supervisor confident quickly?

A single mapping from obligation to control owner to evidence location, plus a clean record of how you handle requests and close remediation. (Regulation (EU) 2022/2554, Article 32)

How do I prevent Security and Procurement from giving inconsistent answers?

Force everything through one intake ID and one evidence pack owner for each request, with Compliance/Legal sign-off before submission. Maintain an evidence index so teams pull the same artifacts.

We already have TPRM. What’s new here?

Article 32 reinforces that ICT third-party risk is overseen through an EU-level structure that can drive cross-sector alignment. (Regulation (EU) 2022/2554, Article 32) Your delta is oversight readiness: response governance, evidence packaging, and remediation closure discipline.

Where does Daydream help without creating another layer of process?

Daydream is strongest where teams usually break: mapping requirements to owners and evidence, managing request intake and approvals, and tracking CAPs with validation artifacts in the same place.