Question ID: DORA 253 - 3393
Regulation Reference: (EU) 2022/2554 - Digital Operational Resilience Act (DORA)
Topic: Register of Information (DORA)
Article: N/A
Status: Final
Date of submission: 25 Jul 2025
Question
If a contract that is included in the ROI as at 31-Mar-2025 is terminated between 1-Apr-2025 and 31-Dec-2025, should it be included in the ROI reported as at 31-Dec-2025 with a reason (B_02.02.0090) filled in? If yes, should the contract be included in the ROI report as at 31-Dec-2026?
EIOPA answer
The information gathered from the Register of Information is essential for financial entities’ internal ICT risk management, for the effective supervision of the financial entities by their competent authorities, and for the establishment and conduct of oversight of the critical ICT third-party providers by the Lead Overseer. For this reason, the information included in the register of information reported by financial entities to competent authorities needs to be updated and enable for comparison year over year. According to Article 4 of the “ESAs Joint Decision of 08 November 2024 concerning the reporting by competent authorities to the ESAs of information necessary for the designation of critical ICT third-party service providers in accordance with Article 31(1)(a) of Regulation (EU) 2022/2554 (ESA 2024 22)” the reference date to report the register from the competent authority to the ESAs is the 31 December of the calendar year preceding the reporting date. In case a contractual arrangement included in the register of information reported with reporting date 31.12.X is terminated in the year X+1, the following apply:
Reporting concerning the year X+1:
The financial entity reports in field “B_02.02.0080” the date of termination of the contractual arrangement and in field “B_02.02.0090” the reason for termination.
Reporting concerning the year X+2:
The financial entity does not report the contractual arrangement terminated in the year X+1.