Ask a fintech founder to sketch their technology stack and the drawing will be mostly other people's logos. Cloud hosting, core banking, card issuing, KYC, fraud scoring, open banking connectivity, customer messaging, data warehousing. Modern financial services are assembled, not built, and that is a large part of why fintechs can launch products in months rather than years.

Your Cloud Provider Is Now Your Regulator's Problem Too: Third-Party Risk in Fintech After DORA

Ask a fintech founder to sketch their technology stack and the drawing will be mostly other people's logos. Cloud hosting, core banking, card issuing, KYC, fraud scoring, open banking connectivity, customer messaging, data warehousing. Modern financial services are assembled, not built, and that is a large part of why fintechs can launch products in months rather than years.

It is also why regulators have shifted their attention so firmly towards third parties. Since the Digital Operational Resilience Act (DORA) began applying in January 2025, financial entities in the EU have been expected to manage ICT third-party risk with the same discipline they apply to credit or liquidity risk. For UK firms, the FCA and PRA operational resilience regime and the critical third parties framework point in the same direction. The message is simple: you can outsource the service, but you cannot outsource the accountability.

What Has Actually Changed

Vendor due diligence is not new. Most regulated firms have long sent security questionnaires to suppliers before signing a contract. What DORA changed is the depth and continuity expected.

• A Register of Information. Financial entities must maintain a structured register of all contractual arrangements with ICT third-party providers, including which functions they support and whether those functions are critical or important. Supervisors collect this data, so it has to be accurate and in the prescribed format.

• Risk assessment before and during the relationship. Firms need to assess concentration risk, substitutability and the provider's own subcontracting chain, not just tick a box at onboarding.

• Contractual requirements. Agreements supporting critical or important functions need specific provisions covering service levels, audit rights, data location, incident notification and exit.

• Exit strategies. Firms must be able to show how they would move away from a critical provider without unacceptable disruption.

None of this is conceptually difficult. The problem is scale. A mid-sized fintech can easily have more than a hundred active ICT suppliers, and every one needs a classification, a risk view, a contract review and an owner.

Why Spreadsheets Stop Working

Most firms start their third-party programme in a spreadsheet, and for the first few dozen suppliers it works. Then the cracks appear.

Questionnaires go out by email and come back as attachments in different formats. Contract renewal dates live in the finance system while risk ratings sit in a separate file. A product team signs up for a new SaaS tool on a company card and nobody in risk hears about it for six months. When the regulator asks for the Register of Information, the compliance team spends weeks reconciling three sources of truth.

The bigger risk is what spreadsheets cannot show. When a major cloud or software provider has an outage or a breach, the first question from the board is: "Which of our services depend on them?" If answering that takes days, the firm has a resilience problem regardless of what its policies say.

What Good Looks Like in 2026

The fintechs handling this well tend to share a few habits.

They Classify Before They Assess

Not every supplier deserves the same scrutiny. Strong programmes tier vendors by the criticality of the function they support and the sensitivity of the data they process, then scale the depth of assessment accordingly. A payroll SaaS and a core ledger provider should not receive the same questionnaire.

They Monitor Continuously

Annual reviews are a minimum, not a goal. Leading firms track changes in a supplier's security posture, certifications, financial health and incident history throughout the year, and trigger reassessment when something changes.

They Connect Vendors to Everything Else

Third-party risk does not sit in isolation. Each supplier links to business services, information assets, controls, incidents and contracts. Firms using dedicated vendor risk management software can see those links in one place, which turns the Register of Information from a quarterly scramble into a by-product of everyday work.

They Test Their Exit Plans

An exit plan that has never been walked through is closer to a hope than a plan. Regular scenario exercises, even short tabletop sessions, reveal where alternative providers, data portability or contractual terms fall short.

The Commercial Upside

It is easy to see all this as cost. But strong third-party oversight has become a commercial asset for fintechs that sell into banks and larger financial institutions. Those buyers face the same regulatory pressure and now push it down their own supply chains. A fintech that can answer a bank's due diligence pack quickly, with evidence, shortens sales cycles and stands out against competitors still assembling answers by hand.

The same applies to investors. Operational resilience questions have moved firmly into due diligence for later-stage funding rounds, and a clean, current view of supplier risk sends a strong signal about how a business is run.

Where to Start

For firms still early in the journey, the priorities are clear:

1. Build a complete inventory of ICT suppliers, including the ones procurement never saw.

2. Classify each by the criticality of the function it supports.

3. Review contracts for critical providers against regulatory requirements.

4. Assign an internal owner for every supplier relationship.

5. Move the whole process onto a single system before the volume makes it impossible.

Fintech will keep being built on partnerships. The firms that thrive will be the ones that can prove, at any moment, that they understand exactly who they depend on and what happens if one of those partners fails.