DORA Updates and Key Insights from ESAs Workshop

On 29 November 2024, shortly before the final deadline, the European Commission published the Implementing Regulation (EU) 2024/2956 in the Official Journal of the EU. It lays down the Implementing Technical Standards (ITS) for the application of DORA, outlining details about the standard templates for the Register of Information.  

The Implementing Regulation will enter into force on 22 December 2024, twenty days after its publication. 

On 18 December 2024, the European Supervisory Authorities (ESAs) held a workshop to discuss lessons learned from the DORA dry run and data quality.  

Key Takeways from the ESAs Workshop

The workshop covered the following topics: 

1.  Overview of the dry run exercise with focus on data quality assurance process and key findings including key lessons learned.
2.  Preparations for official reporting in 2025 of the registers of information including key changes in the requirements for the registers following the adoption of the ITS. 

Below, we summarize the key updates and insights discussed during the ESAs workshop on DORA. 

Dry Run Overview 

1. Key takeaways for future reporting:  

• Follow Final ITS Instructions: Financial entities are encouraged to follow instructions provided in the final ITS. The ESAs underlined that all materials and tools published on 31 May and later in the context of the dry run exercise were meant solely for the dry run exercise. 

• Prioritize Data Quality Over Completeness: Where a trade-off between data quality or completeness needs to be made, financial entities should prioritize data quality. 

• Importance for the use of Identifiers: The use of identifiers is crucial for the registers and critical third-party providers (CTPP) designation. 

 

2. Top 3 Dry run statistics  

• Total number of financial entities (Fes) covered: 3,447 

• 6.5% successfully passed all data quality checks, while 50% of the others failed less than 5 out of 116 data quality checks 

• Missing mandatory data fields most common error – in line with ‘best efforts’ basis 

Changes to the ITS on the Register of Information 

1.Updated ITS 

The implementing technical standards (ITS) developed by the ESAs which has been adopted by the European Commission on 29 November as Commission Implementing Regulation (EU) 

 The updates include the following: 

Source

 

2.Only “live” contracts are part of the Register of Information (RoI).

3.Unique Identifier is required: EU Commission has introduced the European Unique Identifiers (EUID) for the identification of ICT third-party service providers:

• “Financial entities shall use a valid and active legal entity identifier (LEI) or the European Unique Identifier referred to in Article 16 of Directive (EU) 2017/1132 (‘EUID’), and where available both of these identifiers, to identify all of their ICT third-party service providers that are legal persons, except for individuals acting in a business capacity”.
• Information about the EUID is available under the Business Register Interconnection System: European e-Justice Portal – Business registers – search for a company in the EU .
• To facilitate the implementation of EUID in the registers of information template B_05.01 has been amended à three additional data fields have been introduced 

4.Data Quality Checks 

The workshop highlighted the importance of validation rules and data quality checks. A complete technical package, including data point model, validation rules and taxonomies is expected to be published before 25 December.  

The ESAs noted minor inconsistencies between the Data Point Model (DPM) taxonomies and the final ITS instructions. These will be clarified through official Q&A, expected to be published in January. 

5. Further points

• Languages: There is no concrete information whether the report shall be in English or national language. In the workshop the ESAs suggested FE to check with the National Competent Authority (NCA) which languages they require.
• Reporting Format: The report will be in csv XBRL format and not in Excel as in the dry run. 

cleversoft DORA Reporting Service

The cleversoft DORA Reporting Service ensures you get a ready-to-submit Register of Information (RoI) in the required csv-XBRL format. The team will update the reporting templates to reflect the latest ESA changes. Legal Entity Identifiers (LEIs) will be automatically filled from the GLEIF database, and an automated connection to the Business Register Interconnection System for European Unique Identifiers (EUIDs) is being explored. In addition, the check for expired contracts will be automatically integrated, so that your reports contain only “live” contracts as required by the regulator. The service integrates validation rules from the ESAs and notifies users of any failed checks, saving you time and ensuring a ready-to-submit report. 

For more details on our DORA reporting services, please visit our website or reach out to our dedicated sales team through our website contact form.