EBA · 2025_7297 Final Q&A

The scope of the regulation described in Article 6 mismatches what is presented as an option in the Annex I, Part 2 of the same regulation

Regulation
Regulation (EU) No 2022/2554 (DORA Reg)
Article
28, para. 9
Topic
Register of information (DORA)
Submitted by
Consultancy firm
Submitted
2025-01-08
Answered
2025-07-25
Answer provided by
ESAs (EBA, ESMA, EIOPA)

Question

Do financial entities must include non-financial entities within the same group in the Register of Information? If not, why is there an option to do so?

Background

Commission Implementing Regulation (EU) 2024/2956 of 29 November 2024 Article 6 "Scope of the register of information at sub-consolidated and consolidated level" clearly states that "A register of information maintained and updated at sub-consolidated and consolidated levels shall include all financial entities and ICT intra-group service providers , which are part of the sub-group and group" which implies that non-financial entities and ICT-unrelated entities within the same group should not be included in the scope of the Registers of Information. However, Annex I Part 2 "Instructions to complete template B_01.02 —List of financial entities within the scope of the register of information " of the same regulation gives an option to select type of financial entity "24. non-financial entity: other" in column code B_01.02.0040. Which causes confusion - if there is no need to include non-financial entities in the scope of the Register of Information, why is there an option to select it?

Answer

While the primary purpose of the template B_01.02 is to provide a complete overview of the financial entities that are part of the group and that are included in the group registers, it should also capture other non-financial group entities relevant to the provision of ICT services. This includes non-financial entities involved in the provision ICT services, such as intra-group service providers (also to be reported in B_05.01), and also non-financial entities that have signed contractual arrangements for the provision of ICT services on behalf of a financial entity in the group (also to be reported in B_03.01).

Original source: European Banking Authority, Q&A ID 2025_7297

This Q&A is published by European Banking Authority and is non-binding. It does not constitute legal advice. Updated weekly from official ESA sources.

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