DORA Reporting
The Digital Operational Resilience Act (DORA) officially “went live” on January 17, 2025, fundamentally altering the compliance landscape for the European financial sector. However, a dangerous misconception persists: many firms view this as the finish line. In reality, while the Act is now active, the true test of operational resilience—and regulatory defensibility—lies in the fast-approaching Q1 2026 reporting deadlines. This is the moment theoretical preparation meets the hard reality of technical submission.
Central to this transition is the Register of Information (RoI). It is vital to distinguish that while the reporting submission window opens in 2026, the mandate to maintain a complete, accurate RoI began on January 17, 2025. This is not mere “best practice” guidance; it is a legislative requirement designed to provide National Competent Authorities (NCAs) and European Supervisory Authorities (ESAs) with a machine-readable map of systemic risk and ICT dependencies across the Union.
The shift required of financial entities is seismic. We are witnessing the end of manual, subjective oversight and the birth of a regime defined by rigorous, automated data reporting. To navigate this, leaders must recognize that DORA is less of a legal “check-the-box” exercise and more of a complex data engineering challenge. Drawing from the latest regulatory dry runs and ESAs feedback, here are five surprising lessons for the road to 2026.
The 15-Template Trap: Complexity Beyond the Spreadsheet
Initial estimates of the RoI’s complexity often fall short of the technical reality. The Register is not a simple flat file; it is a sophisticated data architecture comprising 15 distinct templates and 105 specific data points. The difficulty lies not just in the volume of data, but in the strict “interconnectivity” mandated by the ESAs’ Data Point Model (DPM).
Regulators expect a highly relational web of information. For instance, a firm cannot simply list a contract; they must demonstrate the explicit link between Contractual Arrangements (RT.02.01), Functions Identification (RT.06.01), and the Entities Making Use of the Provided ICT Services (RT.04.01). If a contract supports a critical function, the data must reflect that relationship across multiple templates with mathematical precision.
“The expected interconnectivity of data point plus the depth of data required will present a challenge for schemes.”
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The LEI is Your Non-Negotiable Digital Passport
The Global Legal Entity Identifier Foundation (GLEIF) has confirmed that the ISO 17442 Legal Entity Identifier (LEI) is the mandatory anchor for DORA reporting. This requirement is absolute, extending beyond primary vendors to include all subcontractors performing critical or important functions. Crucially, GLEIF suggests that these LEIs be renewed at least once a year to ensure that the global reference data—the “who is who” and “who owns whom”—remains current.
Utilizing the LEI streamlines the reporting process by eliminating the need to submit redundant data points, such as legal names and registered addresses, which are already verified within the global LEI index. Looking ahead, the “verifiable LEI (vLEI)” offers a cryptographic evolution for authenticating the “identification of individuals acting in a professional capacity.” This will allow authorized representatives of third-party providers to sign off on disclosures with verifiable digital credentials, adding a layer of trust to the supply chain.
The “Spreadsheet Era” is Officially Over
The move to the xBRL-CSV format for submissions has effectively killed the manual spreadsheet. Compliance has transitioned from a legal task to a data engineering one. The 2026 reporting cycle highlights why: the March 21 and March 22 deadlines set by NCAs in Malta and the Netherlands, respectively, are not arbitrary. These dates are meticulously timed to allow NCAs to process and validate data before the “onward transmission” to the ESAs by the final end-of-March deadline.
To meet these windows, firms must establish a “single source of truth” that consolidates data from procurement, legal, and ICT risk management. Maintaining this manually is no longer sustainable; it requires technology-enabled capabilities that can automate xBRL-CSV generation while applying mandatory data quality controls—such as duplicate detection and LEI format validation—long before the submission button is pressed.
Lessons from the 2024 “Dry Run” Wake-Up Call
The 2024 dry run exercise conducted by the ESAs (EBA, EIOPA, and ESMA) served as a critical stress test for both the industry and the regulatory machinery. The findings were a significant wake-up call, revealing that many financial entities were fundamentally unprepared for the technical validation rules and business checks applied by the EBA.
The dry run highlighted that the primary point of friction was the conversion of internal records into the xBRL-CSV format. Many participants struggled with technical errors that would have resulted in immediate rejection during an official filing. This exercise proved that data quality checks cannot be an afterthought; they must be embedded into the data architecture to ensure that the information provided is not only accurate but also structurally compliant with the EBA’s technical validation logic.
Conclusion: A Living Register for a Resilient Future
The Register of Information must not be treated as a seasonal compliance exercise. For the RoI to be effective—and for the entity to remain compliant—it must become a “living register.” This means embedding update protocols into the very fabric of business-as-usual: capturing LEIs during onboarding, updating criticality assessments during contract amendments, and recording termination dates immediately upon exit.
As your organization prepares for the 2026 submission, the strategic question is no longer about “if” you can report, but “how” you manage the underlying data. Is your organization viewing DORA as a seasonal reporting hurdle, or as the foundational data architecture for your long-term digital survival?