Supervisory ICT Risk and Cybersecurity Circulars

Among the main pressure points, the MFSA highlighted weaknesses in business continuity, incident handling, patch and vulnerability management, and contractual controls for ICT outsourcing arrangements. It also noted that overreliance on unverified generative AI in submissions can create generic or inaccurate materials that slow down authorisation processes.

The MFSA’s latest ICT circulars underline a clear supervisory focus on digital operational resilience, with particular scrutiny on authorisation applications, TLPT provider standards, and emerging cyber threat awareness. The message is that firms need stronger, more tailored documentation and a better practical grasp of DORA requirements, especially around ICT risk management and third-party oversight.

Among the main pressure points, the MFSA highlighted weaknesses in business continuity, incident handling, patch and vulnerability management, and contractual controls for ICT outsourcing arrangements. It also noted that overreliance on unverified generative AI in submissions can create generic or inaccurate materials that slow down authorisation processes.

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Kane Sammut Henwood

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Legal Intern

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Joeline Barbara

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Junior Associate

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More about MK Fintech Partners Ltd.

Michael Kyprianou Fintech Partners Ltd. is a Maltese company providing services in the FinTech sector. It comprises a team of dedicated experts who provide services such as Legal Advisory, Crypto Licensing, Token Issuers’ Licensing, Investment Services Licensing, and registrations of activities related to Fintech, Crypto, Blockchain & Data Protection, Investment Funds Services & Banking, Company Incorporations, and M&As.

MK Fintech Partners forms part of the Michael Kyprianou Group, a top tier international legal and advisory firm. It has established an enviable reputation as a broad-based legal practice over the years. Mainly by keeping at heart its principle to always exceed its clients’ expectations. MK has grown to become one of the largest law firms in Cyprus with offices in Nicosia, Limassol and Paphos. The MK Group’s international presence also includes fully-fledged offices in Greece (Athens and Thessaloniki), Malta (Birkirkara), Ukraine (Kiev), the United Arab Emirates (Dubai), United Kingdom (London), Israel (Tel Aviv), and Germany (Frankfurt).

The content of this article is valid  at the date of its first publication. It intends to provide a general guide to the subject matter and does not constitute legal advice. We recommend that you seek professional advice on a specific matter before acting on any information you read. For further information, contact us at MK Fintech Partners via email at contactmkfintech@kyprianou.com or by telephone +356 9905 6193.