Question ID: 3480 - DORA 282
Regulation Reference: (EU) 2022/2554 - Digital Operational Resilience Act (DORA)
Topic: Register of Information (DORA)
Status: Final
Date of submission: 11 Dec 2025
Question
In the situation where we have 2 entries in B.01.02 with different C0100 currencies and there is an intra-group contracts between them, which currency should be used in B.02.01 C0040? Should it be the currency of the buyer of ICT services or the currency or the supplier?
Background of the question
The LOG guidance for B.02.01 C0050 (which relates to C0040) states 'The annual expense cost shall be expressed in the currency reported in B.01.02 C0040'. We presume this is a mistake and this is C0100 and not C0040, however if both sides of the contract are in B.01.02 with different currencies, we are not clear which to use.
EIOPA answer
The reference to "B_01.02 C0040" in the instructions for template B_02.01 C0050 is a typographical error. The correct cross-reference is B_01.02 C0100, which identifies the currency used by the financial entity for the preparation of its financial statements.
In the case of intra-group contractual arrangements where the entities involved report different currencies in template B_01.02 C0100, the currency to be reported in template B_02.01 C0040 should be the currency of the financial entity making use of the ICT services (i.e. the buyer). The value reported in B_02.01 C0050 should reflect the amount the buyer spent on ICT services, and the currency and the expense must be consistent with one another.