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European Insurance and Occupational Pensions Authority

DORA039 - 2990

Q&A

Question ID: DORA039 - 2990

Regulation Reference: (EU) 2022/2554 - Digital Operational Resilience Act (DORA)

Topic: Register of Information (DORA)

Article: Article 6(1) ITS 2024/2956

Status: Final

Date of submission: 14 Feb 2024

Question

Is a parent company that is not a financial entity itself required to maintain the information register?

EIOPA answer

The obligation to keep registers of information applies only to financial entities in scope of DORA. Therefore, if the parent undertaking is not a financial entity, the obligation does not apply to the parent undertaking at individual level.

However, in accordance with Article 6(1) ITS 2024/2956, the parent undertaking of financial entities that are part of a group should determine the entities to be included in the register of information at sub-consolidated and consolidated level.

To reduce administrative costs of groups, groups should have the possibility to develop a single register of information at entity, sub-consolidated and consolidated levels in relation to all contractual arrangements on the use of ICT services provided by ICT third-party service providers to all the financial entities that are part of that group. In such cases, the single register of information should allow each financial entity to comply with its obligation to maintain and update the register of information at entity and sub- consolidated level, where applicable, including its reporting to its competent authority.