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Q&As refer to the provisions in force on the day of their publication. The EBA does not systematically review published Q&As following the amendment of legislative acts. Users of the Q&A tool should therefore check the date of publication of the Q&A and whether the provisions referred to in the answer remain the same.

Please note that the Q&As related to the supervisory benchmarking exercises have been moved to the dedicated handbook page. You can submit Q&As on this topic here.

List of Q&A's

Obligation to maintain a register of information for FEs exempt under article 16

 Are financial entities, which according to article 16(1) in DORA are excluded from application of Articles 5 to 15, also are excluded from application of article 28 of DORA?    

  • Legal act: Regulation (EU) No 2022/2554 (DORA Reg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

How to fill the refPeriod field of the parameters.csv file for the DORA register of information

As part of the DORA register of information packaging process, we are required to include a parameters.csv file that contains a refPeriod field. Could you please confirm what specific date should be used for the refPeriod?

  • Legal act: Regulation (EU) No 2022/2554 (DORA Reg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/2956 - ITS on the register of information

ANNUAL REPORT ON NEW ARRANGEMENTS ON THE USE OF ICT SERVICES

Does Article 28(3) DORA require a separate and specific communication in addition to the Register of Information, or whether the communication of such data is already fulfilled through the annual submission of the same Register, constituting a single compliance obligation? In the event that a separate communication is required in addition to the annual submission of the Register of Information, what is the meaning of the term 'categories of third-party ICT service providers'?

  • Legal act: Regulation (EU) No 2022/2554 (DORA Reg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/2956 - ITS on the register of information

Identification of ICT Service Providers

Can the ESAs confirm there is no expectation to capture within the Register of Information the ICT subcontractors of non-ICT service providers?

  • Legal act: Regulation (EU) No 2022/2554 (DORA Reg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable