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  1. Home
  2. Single Rulebook Q&A
  3. 2025_7297 The scope of the regulation described in Article 6 mismatches what is presented as an option in the Annex I, Part 2 of the same regulation
Question ID
2025_7297
Legal act
Regulation (EU) No 2022/2554 (DORA Reg)
Topic
Register of information (DORA)
Article
28
Paragraph
9
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Regulation (EU) 2024/2956 - ITS on the register of information
Article/Paragraph
Annex I, Part 2, Instructions to complete template B_01.02 —List of financial entities within the scope of the register of information, Column Code B_01.02.0040
Type of submitter
Consultancy firm
Subject matter
The scope of the regulation described in Article 6 mismatches what is presented as an option in the Annex I, Part 2 of the same regulation
Question

Do financial entities must include non-financial entities within the same group in the Register of Information?

If not, why is there an option to do so?

Background on the question

Commission Implementing Regulation (EU) 2024/2956 of 29 November 2024 Article 6 "Scope of the register of information at sub-consolidated and consolidated level" clearly states that "A register of information maintained and updated at sub-consolidated and consolidated levels shall include all financial entities and ICT intra-group service providers, which are part of the sub-group and group" which implies that non-financial entities and ICT-unrelated entities within the same group should not be included in the scope of the Registers of Information.

However, Annex I Part 2 "Instructions to complete template B_01.02 —List of financial entities within the scope of the register of information" of the same regulation gives an option to select type of financial entity "24. non-financial entity: other" in column code B_01.02.0040.

Which causes confusion - if there is no need to include non-financial entities in the scope of the Register of Information, why is there an option to select it?

 

Submission date
08/01/2025
Status
Question under review
Answer prepared by
Answer prepared by the Joint ESAs Q&A

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