Regulatory Alerts2026-03-12
Q&A Session on the DORA Information Register
The Dutch Financial Markets Authority (AFM) issued this Q&A to clarify the March 2026 submission requirements for the DORA Information Register, mandating that all financial entities report contractual agreements with third-party ICT service providers in xBRL-CSV format via the AFM portal. The document details strict EBA-enforced validation rules, including specific file naming conventions, referential integrity checks, mandatory technical codes for dropdown fields, and precise protocols for handling subcontractors, intra-group outsourcing, and entities without LEI codes. It further confirms that free services without contracts are exempt from reporting, digital advertising platforms fall within DORA's scope, and the EBA's FAQ and Data Point Model take precedence over the ITS during the validation process.