Next week (1- 4 April 2025), all financial entities in scope of DORA are required to submit their first Register of Information (“RoI”) on the Central Bank of Ireland’s Portal (the “Portal”). With the four-day filing window now in sight, further guidance continues to be released by both the Central Bank of Ireland and the European Supervisory Authorities (“ESAs”) on how the various files that make up the RoI reporting package should be prepared and how the final RoI should be filed.

Updated RoI Templates

Arthur Cox continues to see many clients using the excel template for the RoI which was issued as part of the 2024 Dry-Run Exercise. While this template does contain the vast majority of data fields required, financial entities need to be aware that additional columns have been added to the RoI subsequently and the definition of certain data fields has been refined.

Note: The Dry-Run template can typically be identified by the naming conventions used in the Column Codes and Tab Names which have the prefix ‘RT.’

Financial entities should be aware that updated templates for the RoI are now available on the European Banking Authority’s website which include all required data fields under the finalised ITS on the registers of information. The two sets of templates now available are as follows:

1. An annotated excel template of the ROI (3.8MB)[1] which may be used to collate and maintain the register on an ongoing basis. While financial entities may choose to maintain a version of the RoI in an human-readable format, for reporting purposes these values will need to be replaced by the codes provided in the data point model with prefix ‘eba’ (XLS,75KB).
2.  A full set of templates for the DORA reporting package (ZIP, 736KB)[2] content including all .csv and .json files which will need to be included within the zip file to be submitted on the Portal.

 All financial entities in scope of DORA should familiarise themselves with the format and requirements of the DORA reporting package as soon as possible, including the short guide on  preparing .csv and .zip files for reporting (PDF,271KB) published by the ESAs.

Updated FAQ on the Reporting of RoIs

An updated FAQ on reporting registers of information under DORA (PDF, 1419 KB) was published by the ESA on 19 March 2025, to update 5 existing questions and to include details of 3 new questions, as summarised below:

Questions Updated

• Q 16: RoIs reported in a language other than English should use UTF-8 character encoding.
• Q 25: The values to be used in the drop-down data files are those outlined in the data point model (see link above).
• Q 27: The link to the overview of the technical checks, validation and business checks performed on the RoI has been revised.
• Q 64: Guidance on how to populate B_04.01.0040 if the financial entity is not a branch.
• Q 107: Further guidance on the treatment of resellers within the RoI.

 Questions Added

• Q 122: Guidance on the treatment of non-life insurance activity classes in B_06.01.0020.
• Q 123: Noting the link between the  functions to be reported in Template B_06.01 and those to be identified based on Article 8(1) of DORA.
• Q 124: Confirming that ‘Not Applicable’ should be populated in B_02.01.0030 when there is no overarching contractual arrangement in place.

The Pensions Authority has also recently updated their Q&A on DORA (PDF,134 KB), to confirm the RoI Template to be used for the 2025 filing as well as providing a decision tree and accompanying notes to assist trustees in assessing which services are to be considered ICT Services (PDF,84KB).

Guide to Submission

The Central Bank have now published their own Guide to Submitting DORA Registers of Information on the Portal (PDF, 2.6 MB), a couple of days later than planned.

As with the reporting package, all financial entities need to familiarise themselves with the contents of the guide as soon as possible, paying particular attention to:

• The three-step process to be followed when submitting the RoI.
• The common validation errors which can lead to an RoI being rejected; and
• The prescribed naming convention to be used in when uploading the finalised zip file to the Portal.

How can we help?

We continue to monitor developments in this space closely and will continue to release updates and further guidance as and when more information becomes available.

For any queries, please contact your usual Arthur Cox contact(s), or any member of the Governance and Consulting Services or Technology and Innovation Groups to discuss how we can help you.

[1] Note: After clicking the link to the annotated excel template, download and search for ‘20241217 Annotated Table Layout DORADORA 4.0’ to access the correct file.

[2] Note: After clicking the link, download the folder, under “instances xBRL-CSV”, search for the DORA file (DUMMYLEI123456789012.CON_FR_DORA010100_DORA_2024-12-31_20241213174803429)