DORA register of information: what must it contain?
DORA requires financial entities to maintain a register of information on all contractual arrangements for ICT services, at entity, sub-consolidated and consolidated level. Supervisors request it annually; it also feeds the designation of critical ICT providers.
Short answer: The register of information is your mandatory, standardised overview of all contractual arrangements for ICT services with third-party providers. You maintain it at entity, sub-consolidated and consolidated level, and the supervisor can request it (annually). It is not a formality — it feeds the EU oversight of critical ICT providers.
What goes in it
Per contractual arrangement: the provider and its identification, the type of ICT service, whether the service supports a critical or important function, the chain of subcontractors/sub-processors, locations of service provision and data processing, and the term/exit conditions. The ESAs have set standardised templates (ITS) so registers are comparable.
Why it matters
The register is also your own steering instrument: it makes dependencies and concentration risk visible (e.g. too many critical services with one cloud provider). And it is the basis on which the ESAs determine which ICT providers are designated critical for direct EU oversight. See Third-party ICT risk and oversight.
Practical
Start with a full inventory of your ICT outsourcing, classify per function (critical/important or not), fill the ITS templates, and set up a process to keep the register current on every new or changed arrangement.
Lees ook: DORA guide and DORA readiness roadmap.
Sources
- https://eur-lex.europa.eu/eli/reg/2022/2554/oj
Regulation (EU) 2022/2554 (DORA), Article 28 — register of contractual arrangements with ICT third-party providers. - https://www.eba.europa.eu/regulation-and-policy/digital-operational-resilience-dora
ESAs — implementing standards (ITS) for the standardised register templates.
Read next
Third-party ICT risk under DORA: contracts, register and oversight
DORA sets requirements for ICT outsourcing: mandatory contract clauses, a register of information on all ICT providers, and an EU oversight framework for ICT providers designated as critical.
AI and digital rules for the financial sector — overview
One entry point for banks, insurers and fintech: which AI and digital rules affect your institution — from DORA and the AI Act to credit scoring, AML and insurance — each with a source-traceable file and the financial scan.
DORA readiness: a roadmap to prepare
DORA has applied since 17 January 2025. A practical roadmap to get a grip: determine scope, map ICT dependencies and the register, set up risk management and incident reporting, plan resilience testing, and review your vendor contracts.