All regulated financial firms
South Korea
On July 29, 2026, South Korea's Financial Supervisory Service (FSS) published third-party IT risk management guidelines applicable to financial firms relying on external IT services including cloud and SaaS providers. The guidance makes the board of directors the final owner of third-party IT risk and assigns management the responsibility for building and maintaining the control framework. Financial firms must regularly update information on outsourced providers' financial condition, security posture, data handling, encryption, incident response, and infrastructure. Providers that could materially affect operations or consumers must be designated as 'major third parties' and reviewed at least twice annually. Firms must also maintain business continuity plans, exit strategies, and verify data return and deletion after contract termination. Industry associations plan to develop sector-specific best practices with implementation expected after November 2026.
Verified from source: The Financial Supervisory Service issued 'third-party IT risk management guidelines for financial companies' to systematically manage risks from expanded use of external IT services such as cloud and SaaS. The guidelines assign the board of directors ultimate responsibility for third-party IT risk management and define roles for management and a central management department.
- Sets a supervisory precedent for board-level accountability over third-party IT risk that could influence other jurisdictions' approach to BaaS oversight
- Financial firms partnering with fintech or BaaS providers in South Korea will need enhanced due diligence and ongoing monitoring frameworks
- The 'major third party' designation concept mirrors emerging global trends (e.g., EU DORA) and may accelerate similar classification regimes elsewhere
- Exit strategy and data deletion requirements will affect how BaaS and SaaS contracts are structured with Korean financial institutions
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