EBA Q&A 2024_7281 on Regulation (EU) 2022/2554 (DORA): Template specific instructions – field B_02.02.0160 (Location of management of the data).
Authority
EBA
Q&A ID
EBA_QA_2024_7281
Topic
Register of information (DORA)
Legal basis
Article 28(9) DORA
Status
Final Q&A
Published
28/03/2025
Submitted
13/12/2024
Source
How to report data field B_02.02.0160 where the ICT service is not based or does not foresee data processing?
The ITS describes field B_02.02.0160 as mandatory only if the ICT service is based on or foresees data processing. According to the data model, however, this field is marked as a primary key and therefore cannot be missing or reported empty. It is unclear how to fill in the data field without triggering a data quality error.
According to the data model for the Register of Information , data field B_02.02.0160 is marked as a primary key value. As result it should not be missing or reported empty. The option ‘Not Applicable’ was added to the closed set of options. If the ICT service is not based / does not foresee data processing, then the option ‘Not Applicable’ should be used. The field should be filled in with the country of data processing otherwise.
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