The Hungarian National Bank (MNB) has issued Recommendation 4/2019 (IV. 1.) of the Magyar Nemzeti Bank
on the usage of community and public cloud computing services – available in English here:  https://www.mnb.hu/letoltes/4-2019-cloud-bg.pdf

Despite its bureaucratic weaknesses, it is overall a helpful summary of best practices targeting financial and capital market institutions, funds, insurance companies and institutions of the financial infrastructure (regulated market, clearing house and central depository).

The recommendation places some administrative burden on financial companies, e.g. article 10 – decisions about using a cloud service should be thoroughly documented. This burden – generally to track the decision making process – seems to be proportionate given the importance of financial and personal data.

Another administrative burden is the pro / con analysis – article 12 which is overly bureaucratic in my view, similar to the documentation requirement of data transfer to third countries in article 19.

Informing the MNB about a cloud service contract, as described in article 29, seems also too bureaucratic.

Overall, the requirements are numerous and only partially justifiable by the related risks, as some of the requirements do not help mitigating the risks, just add administrative burdens.

The Recommendation still helps Hungarian financial institutions planing the setting up a cloud service solution and reminds them to plan ahead for an eventual termination of the service.

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