Register of Information (DORA)
The Register of Information under DORA is the mandated catalog of ICT third-party service arrangements that financial entities must maintain and submit to competent authorities, providing sector-wide visibility into ICT dependencies.
What the Register Actually Contains
The Register captures detailed information about ICT third-party arrangements: the identity and jurisdiction of the service provider, the nature and function of the service, the criticality of the function supported (in particular whether it supports a critical or important function), subcontracting arrangements, and various risk and continuity attributes.
The specific data elements are defined in DORA's regulatory technical standards, which require a substantial degree of granularity. Simple vendor lists do not satisfy the requirement.
Why the Register Matters
The Register serves multiple purposes at once. Individually, it forces financial entities to maintain a rigorous view of their ICT third-party dependencies. Collectively, it gives regulators sector-wide visibility into concentration and systemic risk. Aggregated Register data can identify providers on whom significant portions of the sector depend, triggering designation as critical ICT third-party service providers.
See ICT concentration risk for the systemic-risk framing.
Operationalizing the Register
Maintaining the Register at scale is a substantial operational undertaking. Most entities integrate Register maintenance with their broader TPRM processes, since the underlying data overlaps heavily. Change management, subcontractor discovery, and data-quality assurance are common challenges.
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