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Should or should DORA not apply to the company if the ancillary insurance intermediary activities are not the company’s principal activity, and based on the revenues from these ancillary insurance intermediary activities (rather than overall revenues), the company does not exceed the criteria for a …

We have a question on FAQ#74 in the DORA preparations document "Frequently asked question on reporting of the registers of information (updated on 19 March 2025)". FAQ 74 is very helpful in understanding how to complete B.02.01, B.02.03, B.05.02 for the mentioned situation. However we are unclear wh…

We have a question on FAQ#102 in the DORA preparations document "Frequently asked question on reporting of the registers of information (updated on 19 March 2025)". This FAQ doesn't seem correct if the intra-group provider is signing contracts on behalf of financial entities in the group, the intra-…

Our understanding is that a multinational business offering financial services and insurance intermediation activities can rely on the exemption under either Article 3(60) micro enterprise, (63) small enterprise or (64) medium-sized enterprise categories under DORA. We have however not been able to …

Can ancillary insurance intermediaries, in light of proportionality, determine their annual turnover based on the income that the ancillary insurance intermediary received from the distribution of insurance products during the year in 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?

Art. 12 III DORA: When restoring backup data using own systems, financial entities shall use ICT systems that are physically and logically segregated from the source ICT system. What does DORA mean by "recovering backed-up data using own systems"? What does "own systems" mean? What is the source ICT system? The productive system whose data is backed-up or the system where the backed-up data is stored?

I would appreciate a clear answer regarding how financial entities should handle situations involving reselling. According to point 107 of the Q&A: "If the reseller is not providing the ICT service on an ongoing basis, it should not be considered an ICT TPP." Given this statement, how should we …

For the identification of insurance and reinsurance undertakings the RTS on TLPT specifies quantitative criteria in Article 2(2)(g) that must be met in a cumulative way. Additionally, in the last subparagraph of Article 2(2) of the RTS on TLPT further quantitative criteria are given. In order to fos…