"Operate freely: maintain in-house the skills required to run, evolve, and audit your systems without excessive reliance on third parties."
Map critical skills, measure outsourcing dependency, build a knowledge transfer plan, and track a human sovereignty indicator.
CDO, CIO, IT HR leads, sourcing managers, architecture teams, data & AI product owners.
Data engineering, MLOps, data governance, cloud architecture, cybersecurity, generative AI, DORA operational knowledge.
Half day (3h30) — 2 sessions + 1 mapping and diagnostics workshop.
Outsourcing technical skills is a short-term efficiency decision that can become a long-term strategic vulnerability. DORA explicitly names this risk.
Financial entities must maintain sufficient internal competence to assess risks related to ICT third-party providers, supervise outsourced services, and exercise audit rights. Internal technical ignorance cannot serve as an alibi for DORA non-compliance.
Art. 30.2.e: effective right of audit and inspection — impossible without internal competence to conduct the audit.
AI models introduce a new form of skills dependency: if only the vendor understands how the model works, the organization can neither audit it, detect its biases, nor assess its EU AI Act compliance. This violates both Right 2 (understand) AND Right 4 (operate freely).
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