Services of credit registers under DORA

Should public Credit Registers be regarded as providers of ICT services under Article 3(19) of DORA?

Credit information systems are typically managed by private credit bureaus. However, in several EU countries, governmental entities, notably through Credit Registers housed within local central banks, may also oversee these systems. For instance, in countries like France, the credit infrastructure is solely operated by the Banque de France. Local banks routinely access the Credit Register online to obtain specific information about borrowers who have sought exposure instruments (i.e., credit) before conducting creditworthiness assessments. They utilise the Banque's customized products for their internal risk assessments.