On May 6, 2025, NLD DNB said most information registers have been accepted for transmission to the European Supervisory Authorities (ESAs).
ESAs will apply additional validation rules and provide feedback to NLD DNB.
NLD DNB will then provide feedback on results; financial institutions must correct errors found and re-report to NLD DNB for acceptance by May 28, 2025 at the latest.
On Jan. 23, NLD DNB issued request for DORA information register.
NLD DNB issued request and deadline for DORA information register in Apr. 2025.
Follows NLD AFM Dec. 2024, updated submission information registers, see #236301.
Submissions for Information Register
Since the entry into force of Digital Operational Resilience Act (DORA), financial institutions must maintain an information register for all contractual agreements.
Specifically on ICT services use provided by third-party providers (DORA art. 28(3)).
To begin European process for designation of critical third-party ICT service providers, financial institutions must submit information register to NLD DNB in Apr. 2025.
Request will be available in MijnDNB from Apr. 1, 2025 via the Service Reports page.
Reference for submissions is Mar. 31, 2025, and institutions must report information register by Apr. 23, 2025 at the latest, using ESAs' format set out by NLD DNB.
European Supervisory Authorities (ESAs) comprise EBA, EIOPA, and ESMA.
Financial institutions unable to complete implementation of xBRL-CSV standard in time should be aware that NLD DNB is making an alternative delivery method available.
The alternative will be worked on this year, so financial institutions wishing to make use of this should report the information register in accordance with DORA template.
Actions Post-Deadline
NLD DNB automatically performs most technical and data quality checks in accordance with validation rules, so financial institutions will receive immediate feedback.
Information registers are made available to the ESAs through NLD DNB.
ESAs also check data quality and, in addition to NLD DNB, ESAs will implement the validation rules on LEI codes and EUIDs, and results will by fed back by NLD DNB.
NLD DNB then expects the errors identified to be corrected by means of a re-report.
Effectiveness
Deadline for submission of information registers to NLD DNB is Apr. 23, 2025.
Mar. 2025 Alternative Delivery Method
On Mar. 25, 2025, NLD DNB said standardized Excel template available to support financial institutions unable to implement xBRL-CSV format submission by deadline.
DORA information register available via reporting service in MyDNB from Apr. 1, 2025.
Deadline for delivery of DORA information register is Apr. 23, 2025.
Apr. 2025 Software Processing Issue
On Apr. 4, 2025, NLD DNB updated on a problem with the software for processing the standardized Excel template caused by the presence of commas in free input fields.
Work underway with software supplier to resolve issued: requested that submissions not to include commas in the free input fields until problem has been resolved.
Apr. 16, 2025 Processing Line Failure
On Apr. 16, 2025, NLD DNB confirmed that it is not possible to report the & character in freely fillable key fields, and asked all users for reports with and written out in full.
For Excel deliveries, these are light yellow fields to the left of table, and only applies to fields in template where Open is filled in, as for example, B_02.03, column A and B.
Apr. 23, 2025 Completion Guidance
On Apr. 23, 2025, NLD DNB issued a new document, in Excel format, containing points of attention for completing and submitting entries to the DORA information register.
NLD DNB had noticed information registers do not pass data quality checks, and are therefore not accepted, if certain steps are not carried out correctly by the compiler.
In the document NLD DNB provides an overview of important sources that can be used as a guideline for information completion, as well as an overview of common mistakes.
The document will be updated whenever further guidance or tips become available.
May 2025 Information Register Status
On May 6, 2025, NLD DNB said most information registers have been accepted for transmission to the European Supervisory Authorities (ESAs).
ESAs will apply additional validation rules and provide feedback to NLD DNB.
NLD DNB will then provide feedback on results; financial institutions must correct errors found and re-report to NLD DNB for acceptance by May 28, 2025 at the latest.
