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Neither a bank-owned data centre nor cloud is automatically better for banking workloads. The right choice depends on the workload’s criticality, recovery needs, jurisdiction, control requirements, provider dependencies, and the bank’s ability to operate and govern the service. Cloud can offer agility and scalable capacity; a directly controlled facility can offer more direct infrastructure control. Neither removes operational, cyber, continuity, or governance risk.
For a bank, the practical question is not simply where servers sit. It is whether the complete service—including its people, systems, suppliers, contracts, recovery arrangements, and exit route—can keep critical operations running through disruption.
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What does “data centre vs cloud” mean for a bank?
A data centre is a physical facility that houses computing, storage, and networking equipment. In a banking comparison, “data centre” often means infrastructure the bank owns or directly controls, but that is not the only arrangement: a bank may lease space in a colocation facility or use privately hosted infrastructure. Those options distribute responsibility differently, so they should not be treated as identical.
Cloud is a service model in which computing resources are provisioned from a provider’s infrastructure. The bank’s level of control depends on the service and deployment model. A service may be dedicated to one customer or shared, and the provider may manage only physical infrastructure or a larger part of the application stack. The label “cloud” alone does not establish where data is stored, who can access it, how recovery works, or which party performs a security task.
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For each option, compare the same workload and service assumptions. A comparison between a fully bank-operated facility and a provider-managed application is not meaningful unless it accounts for the different responsibilities, service boundaries, and costs.
Is cloud computing safe for banks?
Cloud can be used for banking workloads, but “safe” depends on the architecture, controls, provider, contract, and bank oversight—not on the hosting label. Outsourcing can provide expertise, service range, flexibility, and potential cost benefits, while also introducing third-party and concentration risks the bank must govern.
The European Banking Authority describes EU Digital Operational Resilience Act (DORA) requirements covering ICT risk management, incident reporting, resilience testing, and third-party oversight. DORA has applied since January 2025; it is an EU framework, not a universal legal requirement. Its existence does not make a cloud deployment compliant by default. The bank still needs to determine which requirements apply to its entity and service, implement controls, and maintain evidence of oversight.
The European Banking Authority reported approximately EUR 6.5 billion in bank losses from new IT-risk events in 2024, compared with approximately EUR 2.8 billion in 2023. It also reported that 58% of surveyed banks had experienced at least one cyber-attack in the second half of 2024, compared with 55% in the first half. These figures demonstrate material ICT and cyber risk; they do not show that cloud or bank-owned data centres are safer, nor do they establish which hosting model caused the reported losses or attacks.
What the bank must continue to own
Using a supplier does not transfer the bank’s responsibility for the service’s impact on its operations. In a 2024 speech, European Central Bank Supervisory Board member Elizabeth McCaul stated: “At the heart of the Guide is the clear expectation for banks to retain full responsibility for their outsourced services.” That principle makes effective governance essential: the bank needs enough information, authority, skills, and contractual access to supervise the service rather than relying on a provider’s assurances alone.
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- Map which service components the provider operates and which remain the bank’s responsibility.
- Assess data protection, access, encryption, key management, logging, and incident notification arrangements.
- Review subcontractors and the chain of dependencies supporting the service.
- Check that continuity plans, recovery capabilities, and contract terms fit the operation’s criticality.
- Maintain an executable way to transfer or replace the service if the provider relationship ends or becomes unsuitable.
Should banks move core banking to the cloud?
There is no blanket answer. A core transaction platform should be assessed against the bank’s own tolerance for disruption, recovery requirements, architecture, jurisdictional obligations, provider arrangements, and operational capability. A claim that all core banking should move—or that it should never move—goes beyond what the available evidence establishes.
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Classify the service by the critical operation it supports before selecting infrastructure. A customer-facing digital service, analytics workload, and core transaction platform may have different recovery objectives, data needs, dependencies, and consequences of interruption. A cloud design that fits one workload may be inappropriate for another.
When cloud may fit
Cloud may be attractive when the bank needs flexible capacity, access to provider services or expertise, or faster provisioning than it can achieve with its existing environment. Those benefits matter only if the bank can also meet its control, resilience, security, and oversight requirements. A provider’s scale is not a substitute for the bank’s workload-specific risk assessment.
When directly controlled infrastructure may fit
A bank-owned or directly controlled environment may suit needs for particular configurations, operational processes, or direct oversight of infrastructure. But control over equipment does not itself prove stronger security or better recovery. The bank must still maintain competent staff, secure and patch systems, protect facilities, test recovery, and address dependencies on utilities, equipment, software, and external suppliers.
When a hybrid design may fit
A hybrid architecture can place different components in different environments to meet defined control, continuity, or capability needs. It also creates integration and governance work: teams must manage connectivity, identity, monitoring, change control, data movement, recovery dependencies, and responsibility across boundaries. “Hybrid” is not a risk-reduction result by itself; it is an architecture that needs its own end-to-end failure and recovery analysis.
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How should banks compare data centres and cloud?
Use a common workload definition and compare the full service, not just the underlying servers. The matrix below identifies questions to answer for both options; the outcome will vary with the architecture, contract, operating model, and bank.
| Decision area | Questions for a bank-owned or directly controlled data centre | Questions for cloud |
|---|---|---|
| Resilience and recovery | Which facility, power, network, hardware, staffing, and supplier failures could interrupt the service? Are backups and alternate recovery capacity independent of the primary failure domain? Have recovery objectives been tested? | Which regions and zones support the service, and what failures do they protect against? What does the provider recover, what must the bank recover, and how do provider-wide outages affect the workload? Are recovery objectives tested end to end? |
| Control and governance | Can the bank configure, observe, change, and recover each layer? Does it have the skills and processes to exercise that control consistently? | Which controls are available to the bank, which are operated by the provider, and how are duties divided? Can the bank obtain enough operational information to oversee the service? |
| Security and data | How are identities, privileged access, encryption, keys, data location, logs, and incident handling managed across the facility and applications? | Where is data stored and processed? Who controls keys and administrative access? Can the bank monitor activity, investigate incidents, and meet applicable data requirements? |
| Third-party and concentration exposure | Which equipment, software, connectivity, facilities, and support are supplied by third parties? Could dependencies shared across services create a common point of failure? | Which providers and subcontractors support the service? Does reliance on one provider extend across other critical bank services? Can the bank and relevant authorities obtain oversight and access? |
| Portability and exit | Can the bank move or rebuild the workload if its facility, technology, or supplier arrangement changes? What data and configurations must be preserved? | Can the bank export data in usable formats, transfer it within required timeframes, and verify deletion? Which services or interfaces create dependencies, and what are the termination rights and migration costs? |
| Economics and capability | What are the full costs of facilities, equipment, energy, staffing, maintenance, refresh cycles, licenses, and unused capacity? Can the bank sustain the necessary expertise? | What are the full costs of migration, recurring usage, licenses, data movement, support, and required controls? How will utilization and changing demand affect cost, and does the bank have cloud-operating skills? |
There is no suitable cross-bank comparison establishing that cloud or data centres are generally superior on cost, availability, or security. The table is therefore a decision framework, not a ranking. A bank should populate it with evidence for its own service, provider, and operating assumptions.
How do resilience and recovery requirements change the decision?
Operational resilience is about delivering critical operations through disruption; it is an outcome, not a property conferred by server location. The Basel Committee on Banking Supervision defines operational resilience as “the ability of a bank to deliver critical operations through disruption.” A resilient design must account for what can fail and show that the operation can continue or recover within an acceptable period.
For each workload, establish the impact of interruption, acceptable recovery time, acceptable data loss, and dependencies that must be restored together. Then test whether the proposed design and operating arrangements achieve those outcomes, including scenarios that affect a provider or a shared dependency rather than only one machine or site.
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Questions to include in recovery planning
- What happens if a facility, region, network route, identity service, or key supplier becomes unavailable?
- Are backups protected from the same failure, access compromise, or administrative domain as production?
- Who declares an incident, makes recovery decisions, communicates with the bank, and restores each service component?
- Does the recovery test include the application, data, interfaces, staff, and operational procedures needed to deliver the critical service?
- Can the bank demonstrate that recovery arrangements work, rather than relying only on a design document or provider statement?
The Basel Committee’s consolidated Operational risk guidelines page presents its displayed material as a draft version under consultation. It summarizes relevant principles and links to original materials; the draft consolidation should not be represented as a final binding rule. The underlying principles emphasize management and board understanding of outsourcing risks, appropriate controls, contingency plans, comprehensive contracts, and access for authorities.
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How do regulation, jurisdiction, and subcontractors affect the choice?
Start with the laws and supervisory requirements that apply to the bank and the particular service. The EU’s DORA framework addresses ICT risk management, incident reporting, resilience testing, and third-party monitoring, and includes an oversight framework for ICT providers designated critical. It applies in the EU context; a bank should not assume the same rules apply worldwide or that using a particular deployment model satisfies them.
Jurisdiction assessment should cover more than the advertised location of a data centre. The bank needs to understand where data is stored and processed, which entities operate the service, what access rights apply, and how location and access commitments are reflected in contracts and operating controls.
Subcontracting matters because the service may depend on more organizations than the contracting provider. For ICT subcontracting supporting critical or important functions, the EBA describes pre-contractual assessment and due diligence, along with monitoring across the subcontracting chain. Its page lists 22 July 2025 as the application date for the final report’s standards. The bank should identify material dependencies, assess how changes are communicated, and determine whether oversight and continuity arrangements extend through the chain.
Provider concentration also deserves attention. The European Banking Authority’s June 2026 Risk Assessment Report says it had received more than 18,000 DORA-related incident reports through March 2026. That is a count of reports received under the reporting regime, not necessarily unique attacks or bank outages. Separately, concentration of important services among a small number of large providers can create broader dependency and potential systemic concerns. A bank should evaluate its own exposure across critical services, not just the provider used by one workload.
What should a bank include in a cloud or data-centre exit plan?
An exit plan should be practical enough to execute, not a statement that the bank could change providers in theory. It should identify what must move, what the replacement environment requires, how operations continue during transition, and how the bank will handle data and contractual obligations.
- Define the exit trigger and authority. Specify the circumstances that could require a transfer or termination, who decides, and who coordinates the bank’s technical, risk, legal, procurement, and business teams.
- Inventory service dependencies. Record applications, data stores, interfaces, identities, keys, provider services, subcontractors, licenses, operational procedures, and staff knowledge needed to operate the workload.
- Set data transfer and deletion terms. Establish export formats, transfer methods, timing, integrity checks, access during transition, and evidence of deletion after the bank no longer needs the data retained.
- Assess replacement capacity. Identify a feasible destination and the network, skills, equipment or services, security controls, and approvals required to run the workload there.
- Plan continuity during migration. Determine how transactions and records remain consistent, how the bank will avoid unacceptable interruption or data loss, and how it will validate the replacement before cutover.
- Test the plan. Use exercises or migration tests proportionate to the service’s criticality, and track issues that could make the plan too slow, costly, or technically unworkable.
Cloud portability can be affected by service-specific interfaces, data formats, and operational dependencies. A bank-owned environment can also have exit challenges when it relies on specialized platforms, supplier support, or skills that are difficult to replace. Include migration and exit costs in the original decision rather than treating them as a problem for later.
How should a bank make the final decision?
Use a documented, workload-by-workload assessment that joins business impact, architecture, risk, compliance, and cost. The result can be a single environment or a deliberately mixed design, but the reasoning should show how the bank can operate and recover the critical service.
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- Set measurable resilience needs. Define recovery time and data-loss objectives, continuity expectations, and the scenarios the design must withstand.
- Describe the complete service. Map facilities or cloud regions, applications, networks, identities, data, providers, subcontractors, and the division of operational duties.
- Assess governance and compliance. Confirm applicable jurisdictional requirements, data controls, contract terms, audit and supervisory access, incident handling, and the bank’s ability to oversee the service.
- Test recovery and exit. Validate recovery procedures and provider-outage assumptions; review whether portability, data transfer, and replacement arrangements are executable.
- Compare whole-life costs and capabilities. Include migration, ongoing operations, staffing, licenses, facilities, utilization, data movement, support, and eventual exit. Confirm the bank can maintain the skills and controls required by the chosen model.
- Record the decision and review it. Document why the architecture meets the workload’s requirements, the risks accepted, the controls and owners, and what changes in service, provider, or regulation would trigger reassessment.
The Basel Committee’s guidance cautions that technology can improve efficiency while also creating technology and infrastructure risks. A sound decision therefore weighs benefits against the bank’s ability to maintain effective controls and contingency plans, rather than treating infrastructure ownership as a proxy for safety.
Frequently Asked Questions
Does DORA require EU banks to use cloud providers?
No. DORA sets digital operational resilience and ICT third-party oversight requirements; it does not, on the evidence cited here, mandate a particular hosting model. Banks should assess their own obligations and service arrangements with qualified compliance counsel.
Is data sovereignty the same as data residency?
No. Data residency usually refers to where data is stored or processed, while sovereignty questions can also involve which legal powers and entities may reach or control it. A location commitment alone does not answer every jurisdiction or access question.
What evidence should a bank request from a provider during due diligence?
Request material that lets the bank assess the actual service boundary, security and recovery controls, subcontracting, incident communication, and audit or supervisory access. The useful evidence depends on the workload and contract; generic certifications or assurances should not replace service-specific oversight.
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No. A directly controlled facility can still depend on equipment, software, connectivity, utilities, maintenance, and specialist suppliers. The bank also retains the staffing, security, continuity, and recovery responsibilities that come with operating the environment.
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