- 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
- Status
-
Question under review
- Answer prepared by
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Answer prepared by the Joint ESAs Q&A