AIST is supportive of the consolidation of business continuity and outsourcing into a single operational risk standard, subject to segmentation of industry-specific clauses and guidance. 

AIST has specific concerns about the materiality of service providers and the expanded role of the Board proposed by the draft standard, the lack of clarifying guidance and the short timeframe for commencement with no transition period. Considerable work will be required to review and upgrade existing outsourcing frameworks which will be difficult to achieve by the 1 January 2024 commencement date.