According to Article 4(2) in the implementing technical standards on the register of information, financial entities shall complete each data element with a single value, and where more than one value is valid for a specific data element, financial entities shall add an additional row in the corresponding template for each valid value. The following information is stated in the answer to question number 36 in the document Frequently asked question on reporting of the registers of information [updated on 14 February 2025] published on the European Banking Authority’s website on preparations for reporting of DORA registers of information. “All rows need to be completely filled. However, financial entities should ensure that additional rows do not introduce duplication of key values (see Data Model for DORA RoI.pdf). Such duplication will be highlighted in the data quality feedback as duplicate values.” It is not clear what is meant by “duplication of key values” in the document referred to above. When adding an additional row to indicate for example an additional location of the data at rest (column code B_02.02.0150), all key values should be repeated in the additional row, including the contractual reference number. Without any repetition of key values, it will not be possible to connect the additional data (for example an additional location of the data at rest) with the contractual reference number. Repetition of key values in another row may also occur when a financial entity reports a different service under the same contractual arrangement. This could be the case if an ICT third-party service provider provides two different software-as-a-service under the same contractual arrangement. In such case, a row in template B_02.02 may, depending on the circumstances in question, have identical values as another row. In the context of this question, it should be noted that both Example A and B in the dry run exercise included repetition of key values in additional rows in the corresponding table. Please confirm that financial entities are allowed to repeat key values when adding an additional row in the corresponding template.

This question has been rejected because the answer is provided in the ITS on Register of Information, Article 4(2):

Where more than one value is valid for a specific data element, financial entities shall add an additional row in the corresponding template for each valid value.