Template specific instructions – primary keys

EBA Q&A 2024_7285 on Regulation (EU) 2022/2554 (DORA): Template specific instructions – primary keys.

Authority	EBA
Q&A ID	EBA_QA_2024_7285
Topic	Register of information (DORA)
Legal basis	Article 28(9) DORA
Status	Final Q&A
Published	28/03/2025
Submitted	13/12/2024
Source	EBA Q&A

Question

How to report data fields in case of missing values?

Background

Some fields are marked as primary keys, and therefore they cannot be missing. However, in some cases the specific field might not be relevant for the entity (e.g., template B_03.02.0010)

Final answer

If financial entities are not able to fill some data fields that are mandatory, they can leave these data fields blank (report empty values), unless the instructions to the data fields or responses to Q&A. provide otherwise (please refer to responses to Q&A 140, 141, 142, 143, 144, 145, 146, 147, 148). These will be highlighted as data quality issues in the data quality feedback.

However, financial entities cannot report empty values for the data fields identified as keys in the data model ( Data Model for DORA Register of Information ). If the financial entity cannot provide a value for a specific field that is identified as a primary key in the data model, financial entity should report ‘Not Applicable’ in that field.