BaFin-compliant cloud usage for financial institutions

Cloud Compliance

Cloud compliance connects applicable requirements with controls, responsibilities and evidence.

  • 01Cloud architectures and governance aligned with applicable supervisory requirements
  • 02DORA compliance and ICT third-party management
  • 03BSI C5 attestation preparation and cloud security audits
  • 04Cloud outsourcing strategies with clear mapping of EBA guidelines and DORA
11+Years of experience
120+Employees
540+Projects
ISO 27001certified

Cloud Compliance

Migrating to the cloud and using cloud services require specialized compliance measures and security concepts. Cloud compliance encompasses adherence to regulatory requirements, data protection provisions, and security standards in cloud environments. We support you in leveraging the benefits of the cloud while simultaneously maintaining the highest security and compliance standards.

We offer comprehensive cloud compliance services covering all aspects of secure and compliant cloud usage. From strategic planning to operational implementation, we support you in shaping your cloud transformation successfully and compliantly.

3 service modules

Service scope

01

Cloud Security Architecture and SLA Management

We develop comprehensive cloud security architectures and implement effective SLA management processes for secure and compliant cloud usage.

  • Design and implementation of cloud security architectures
  • Development of SLA frameworks and vendor management processes
  • Implementation of cloud access controls and identity management
  • Establishment of cloud monitoring and alerting systems
02

Cloud Audits and Certifications

We conduct cloud security audits and support preparation for ISO 27001 certification and SOC 2 examinations. Scope and examination type are defined around the service and required evidence.

  • Conducting cloud security assessments and penetration tests
  • Preparation and support for ISO 27001 certification and SOC 2 examinations
  • Cloud provider audits and due diligence processes
  • Compliance reporting and stakeholder communication
03

Multi-Cloud and Hybrid Cloud Governance

We support you in developing and implementing governance strategies for complex multi-cloud and hybrid cloud environments.

  • Development of multi-cloud governance frameworks
  • Hybrid cloud integration and orchestration
  • Cloud workload migration and compliance mapping
  • Cross-cloud security monitoring and incident response

5 phases

Our Approach

Together with you, we develop a tailored Cloud Compliance strategy that takes into account your specific business requirements and regulatory obligations. We start with the institution, services, data and available evidence, then agree assessment scope, priorities and responsibilities.

  1. Conducting a comprehensive cloud readiness and compliance gap analysis

  2. Developing a strategic cloud compliance roadmap and governance frameworks

  3. Implementing cloud security controls and monitoring systems

  4. Optimizing vendor management and SLA governance processes

  5. Continuous monitoring, validation, and further development of cloud compliance measures

Your contact

Melanie Düring

Head of Risk Management

The cloud offers organizations enormous potential for innovation and efficiency. With the right compliance strategy, organizations can utilize these benefits without compromising on security or regulatory conformity.
ADVISORI expert opinion

Our Strengths

  • 01Deep expertise in cloud technologies and regulatory requirements
  • 02Many years of experience with all major cloud platforms and hybrid architectures
  • 03Comprehensive approach to cloud security, governance, and compliance
  • 04Practical experience with cloud transformation projects in regulated industries

Expert Tip

Successful cloud compliance requires not only technical measures but also a clear governance strategy that accounts for both the shared responsibilities with cloud providers and the specific regulatory requirements of your industry.

7 QUESTIONS, BRIEFLY ANSWERED

Frequently asked questions about Cloud Compliance

What is cloud compliance and why is it critical for banks?

Cloud compliance means implementing the legal, contractual and internal requirements applicable to a cloud deployment and retaining evidence that they are met. Cloud security protects data and systems; governance assigns responsibilities and decisions. Technical security alone therefore does not cover every compliance obligation.

For banks, the entity type, supported business function, data and service providers matter. Financial entities subject to DORA remain responsible for their obligations when using external ICT services. A provider's attestation does not replace the customer's risk assessment, secure configuration, contracts or ongoing oversight. ADVISORI combines this assessment with cloud governance and technical controls, with a focus on EU and German financial-sector requirements.

What BaFin requirements apply to cloud usage by financial institutions?

First determine which rules apply to the institution and the specific cloud service. For entities within DORA's scope, DORA governs ICT risk management and ICT third-party risks. BAIT do not apply additionally to institutions required to operate ICT risk management under the relevant DORA provisions; transitional requirements can still matter for other institutions in 2026.

Assess risk, contracts and controls, data processing, outsourcing classification and supervisory responsibilities. The DORA register of information covers contractual arrangements for ICT services; maintenance, coverage and current submission instructions require separate attention. A blanket statement that this obligation first began in March 2026 is inaccurate.

Source: Bundesbank: BAIT / DORA.

How does ADVISORI support DORA-compliant cloud governance?

ADVISORI supports ICT risk management, cloud governance, provider assessment, the register of information and coordinated control and incident-reporting processes. Scope depends on the institution, cloud services and supported functions.

DORA distinguishes general ICT contract requirements from additional requirements for services supporting critical or important functions. Relevant topics include service scope, subcontracting, processing locations, control rights, incident assistance and exit provisions. A SaaS contract should therefore not be approved solely on the basis of a provider logo or certificate.

Illustrative example, not a customer case: For cloud document storage, record who operates the platform, who approves users and roles, and who reviews changes. Evidence can include applicable provider reports, customer configuration records and documented access reviews. Link each item to a service, date and responsible owner. TLPT is a separate testing scope for designated financial entities, not an automatic part of every cloud consulting engagement.

Legal source: DORA, particularly Articles 28–30.

What is the BSI C5 attestation and when do financial institutions need it?

C5 is a BSI catalogue of information-security criteria for cloud services. An attestation follows an independent examination; it is not a certificate issued by BSI. Review the service and scope, catalogue version, assessment period, exceptions and controls the customer must operate.

Type 1 and Type 2 differ in their point-in-time assessment and examination of operating effectiveness over a period. This does not establish a universal requirement for every financial institution to obtain a particular type or meet a fixed minimum duration. Evidence needs depend on the deployment and applicable requirements; the customer's risk assessment remains necessary. ADVISORI supports report evaluation, gap assessment and examination preparation.

Source: BSI: C5 criteria catalogue.

What role do EBA outsourcing guidelines play in cloud compliance?

The EBA outsourcing guidelines (EBA/GL/2019/02) provide a reference for outsourcing governance, risk analysis, contracts, monitoring and exit planning. For cloud services, assess their relationship with DORA and the national requirements applying to the institution. Not every ICT service is also an outsourcing arrangement, so DORA ICT third-party obligations must not depend solely on an existing outsourcing classification.

Distinguish the institution, service, supported function and applicable framework in the assessment. A consultation on revised guidelines is not an applicable final version. ADVISORI supports this mapping and consistent processes without unnecessarily duplicating the same evidence.

How is multi-cloud governance ensured in regulated environments?

Multi-cloud governance combines common policies with each service's technical features. ADVISORI supports central policies, monitoring, infrastructure-as-code controls and provider assessment. Translate common requirements into controls actually available across AWS, Azure, Google Cloud and SaaS services.

For each control, record the requirement, service, owner, test method, evidence and outstanding exception. Automated checks can detect public sharing or missing logging; contractual rights, lawful processing and organisational approvals need further assessment. A green dashboard proves only the tested criteria within its coverage.

Map storage and processing locations, support access and subcontractors. An EU data centre alone does not settle every privacy or international-transfer question. Multi-cloud is not an automatic compliance guarantee and can introduce additional dependencies.

What steps does a cloud compliance roadmap for banks include?

The existing roadmap covers inventory and gap assessment, governance and responsibilities, technical controls, provider management and ongoing monitoring. Record the starting point, agreed outputs, owners and unresolved decisions for each stage.

For ICT services supporting critical or important functions, exit planning forms part of the DORA assessment. In practice, examine data export, usable formats, restoration, access changes and a realistic transition. A written plan alone does not show that a switch will work: record suitable tests and their limitations.

For an initial inquiry, describe the institution, cloud providers and services, business functions, data categories, existing contracts and available examination reports. Effort depends on service count and complexity, evidence gaps, contractual and integration work, and testing scope. Delivery scope and costs are agreed accordingly; sensitive original data is not needed for the first inquiry.