Reporting DORA registers of information
On 23 January, we announced the reporting request for DORA information registers in April 2025 (link). Information registers must be reported as an xBRL-CSV file. To support financial institutions that are unable to implement this standard on time, we are making an alternative delivery method available this year in the form of a standardised Excel template. Below are some points for attention with respect to completing the report, in response to questions from the sector.
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The reporting request for reporting DORA registers of information will be available from 1 April 2025 in MyDNB (via the Reporting Service). The deadline for reporting is 23 April 2025. If you intend to use the Excel template, you can find it here. The template is also available in the reporting request under Alternative submission in Excel.
You remain responsible for the accuracy and completeness of the reported information at all times. To ensure we can convert the Excel template to the xBRL-CSV standard correctly, it is important to keep the following in mind:
TOC tab
The Excel template contains the "TOC" tab. This is a crucial tab for a correct conversion to xBRL-CSV. It contains several variables.
- Period start: the pre-filled date is 2024-01-01. You do not have to change this.
- Period end: This refers to the reference date, and must be set at 2025-03-31.
- Identifier: You must report at individual or consolidated level. This is indicated in the name of the reporting request. In this field, enter the LEI code of the reporting financial institution, followed by .IND or .CON for individual or consolidated reporting, respectively. For example: DUMMYLEI123456789012.CON for consolidated or DUMMYLEI123456789012.IND for individual reporting.
- Scheme: This indicates the identifier The EBA requires https://eurofiling.info/eu/rs to be entered here.
- Currency: The default monetary unit for reporting is entered here. In most cases this will be EUR.
- Language: This refers to the language of the template, which is en by default. You do not have to change this.
- Table of contents, cells D14-D28: here you specify whether a table is reported or not. Because the reporting requirement specifies that all templates must be reported, even when empty (e.g. form B_01.03 when there are no branches), these cells must all be set to positive.
See the EBA XBRL filing rules for more information.
Tabs
- Conversion: When using the Excel template, it is important not to change the order of the tabs. Adding, removing or moving tabs will lead to errors in the conversion.
- Link: Tabs B_02.03, B_03.01 and B_03.03 include the 'link’ column. This column is not part of the technical standard, but it is crucial for correct conversion to xBRL-CSV. The value true (in lower case) must in all cases be entered here.
- Recipient of the subcontracted services (variable B_05.02.0060): In the B_05.02 tab, the identifier of the receiver of ICT services from a subcontractor must be entered in column D. This cell remains empty if the rank (rank in supply chain) in cell B_05.02.0050 is equal to 1.
- Licenced activity (variable B_06.01.0020): Tab B_06.01 includes the 'licenced activity' column. The dropdown shows the different options in line with the ESAs' reporting standard. If you undertake activities covered by the Solvency II classes of non-life insurance miscellaneous financial loss, legal expenses or assistance, you must select the option Non-Life Insurance: All classes, at the choice of the Member States, which shall notify the other Member States and the Commission of their choice.
Validation rules
- 1 and EBA_CSV_2.26: signals on EBA_CSV_1.1 and EBA_CSV_2.26 can be ignored if you use the Excel template, these issues will be resolved when the reports are forwarded. You do not have to take action on this.
- LEI and EUID: You will receive initial validation feedback from DNB immediately upon submission. We will forward the information register reports to the ESAs. In addition to our validation checks, the ESAs will check the validation rules with respect to LEI codes and EUIDs. We will also forward these results back to you. In the case of errors, you can correct these by resubmitting your report.
- Correcting validation errors: After submission, you will immediately receive an Excel validation report through the Reporting Service You need to correct the unsatisfied results on the Filing Rules and Formula Assertions (Details) You must correct these results even if the report has the status Accepted.
Resubmission
- Please note, new functionality: it is possible to request a resubmission yourself for this report. To do so, you can use the re-report button, in the details of the Reporting obligation
- Resubmission: Given the short timelines, you are explicitly requested to process the results from the validation report before 29 April 2025 and resubmit your report if necessary. We will then forward the information register reports to the ESAs. You can resubmit any reports as a result of EBA feedback to DNB from 1 May 2025. By 28 May 2025, you must have resolved all unsatisfied results by resubmitting your report to us.
More information
We regularly communicate relevant developments related to DORA. Go to www.dnb.nl/DORA for more information on DORA.
Information on consolidated submissions can be found in our initial announcement, which also indicates that banks under the direct supervision of the ECB must report the information register at a consolidated level to the ECB.
The European supervisory authorities (ESAs) have provided a website with a set of resources to prepare for the reporting of DORA registers of information, including the applicable validation rules and a selection of frequently asked questions.