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
Final publishing date
Final answer

While the primary purpose of the template B_01.02 is to provide a complete overview of the financial entities that are part of the group and that are included in the group registers, it should also capture other non-financial group entities relevant to the provision of ICT services. This includes non-financial entities involved in the provision ICT services, such as intra-group service providers (also to be reported in B_05.01), and also non-financial entities that have signed contractual arrangements for the provision of ICT services on behalf of a financial entity in the group (also to be reported in B_03.01).

Status
Final Q&A
Answer prepared by
Answer prepared by the Joint ESAs Q&A

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