What “material outsourcing” should mean in practice
Fintech registers frequently treat every supplier as equal: a stationery vendor sits next to the cloud platform that hosts customer balances. That inventory is useful — and incomplete.
When reviewers ask about material outsourcing, they want to know which arrangements can disrupt critical services, who owns the relationship, how often risk is reassessed, and what happens if the vendor fails. An outsourcing risk audit starts there: materiality criteria, owners, evidence — then contracts.
If your policy cannot name why an arrangement is material, the framework is unfinished regardless of how many vendors appear on the list.