Launch of the new PolishCloud 3.0 Standard

Published on 14th November 2025

We are pleased to announce the launch of the new PolishCloud 3.0 Standard, developed by the Polish banking sector through collaboration between the Council for Electronic Banking, the Banking Technology Forum, Osborne Clarke, and Accenture.

At Osborne Clarke, Szymon Ciach, Counsel in the IT & Data team in Warsaw, coordinated the Legal Stream. The editorial team included: Olga Cabak-Lipska (Associate), Kamil Prokopowicz (Associate), Aleksandra Gajda (Junior Associate) and Norbert Lutowski (Junior Associate).

The PolishCloud 3.0 Standard provides a comprehensive response to significant regulatory and technological changes, particularly those related to the implementation of the DORA Regulation, the AI Act, as well as the withdrawal of the 2020 Cloud Communication and Recommendation D by the supervisory authority.

The document provides recommendations for using cloud computing technologies in the banking sector, aligned with current domestic and international requirements. It defines the tasks, procedures, and processes that financial institutions should implement and document to ensure operational and regulatory compliance for cloud services.

Compared to PolishCloud Standard 2.0, this version emphasizes cloud environment management, including multi-cloud models and vendor concentration risk.
The authors highlight key aspects of data security, business continuity, and strengthening cyber resilience within the Polish banking sector, considering the dynamic geopolitical landscape. The Standard also addresses challenges from the increasing use of artificial intelligence in cloud environments.

PolishCloud 3.0 represents unique collaboration among experts from the banking, technology, and legal sectors. The shared goal was to develop a document that enables financial institutions to use cloud technologies effectively, securely, and in full regulatory compliance — benefiting both organizations and their clients.

Osborne Clarke thanks all institutions and experts involved in preparing the PolishCloud 3.0 Standard — particularly the Council for Electronic Banking, the Banking Technology Forum, Accenture, and all banking sector representatives who contributed their knowledge, experience, and commitment to this project.

We invite you to read the full PolishCloud 3.0 Standard at the following link.

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