> For the complete documentation index, see [llms.txt](https://www.mica.wtf/llms.txt). Markdown versions of documentation pages are available by appending `.md` to page URLs; this page is available as [Markdown](https://www.mica.wtf/eu-level/q-and-a/eba-qa-2025-7297-the-scope-of-the-regulation-described-in-article-6-mismatche.md).

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

|                        |                                                                                                                                                          |
| ---------------------- | -------------------------------------------------------------------------------------------------------------------------------------------------------- |
| **Authority**          | EBA                                                                                                                                                      |
| **Q\&A ID**            | EBA\_QA\_2025\_7297                                                                                                                                      |
| **Topic**              | Register of information (DORA)                                                                                                                           |
| **Legal basis**        | [Article 28(9)](https://www.mica.wtf/dora/digital-operational-resilience-act/chapter-v-managing-ict-third-party-risk/article-28-general-principles) 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](https://www.eba.europa.eu/single-rule-book-qa/qna/view/publicId/2025_7297)                                                                    |

## 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).


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