Last year, investment fund managers (IFMs) were caught by surprise with the immediate application of Circular 17/654 on IT outsourcing relying on a cloud computing infrastructure (the Cloud Circular), but every cloud has a silver lining. Circular 19/714, which amends the Cloud Circular, significantly reduces and clarifies the obligations of IFMs.

This article aims at providing a reminder to IFMs of the rules applicable to them in relation to their cloud computing solutions exactly 6 months before the end of the grace period to establish their cloud outsourcing register (due by 27 March 2019).