The scope of the regulation described in Article 6 mismat...

EBA Q&A 2025_7297 on Regulation (EU) 2022/2554 (DORA): 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.

Authority	EBA
Q&A ID	EBA_QA_2025_7297
Topic	Register of information (DORA)
Legal basis	Article 28(9) DORA
Status	Final Q&A
Published	25/07/2025
Submitted	08/01/2025
Answer prepared by	Answer prepared by the Joint ESAs Q&A
Source	EBA Q&A

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

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?

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).