News 04/11/25

Request for DORA Register of Information in December 2025

For 2026, the Dutch Authority for the Financial Markets (AFM) will once again request the Register of Information from companies subject to DORA. As in 2025, the AFM and De Nederlandsche Bank (DNB) are responsible for collecting the Register of Information in the Netherlands. Unlike the 2025 requets, companies will now be required to submit the registers themselves in the correct format.

The information we receive will be forwarded to the European Supervisory Authorities (EBA, EIOPA, and ESMA). These authorities use the registers to determine which third-party ICT service providers are considered ‘critical’. These critical third-party providers will then fall under the direct supervision of the European Supervisory Authorities.

Request in December 2025, Deadline March 22, 2026

To ensure timely submission to the European authorities, we ask companies to send us their complete Register of Information no later than March 22, 2026. Companies required to submit the register will receive a formal request in December 2025. This request will include instructions on how to submit the register to the AFM.

Submission Format: xBRL-CSV

As previously mentioned, last year we offered a one-time service to convert Excel files to xBRL-CSV. This time, companies are required to submit the register themselves in the correct xBRL-CSV format. If we receive the register in a different format, we will not be able to forward it and will need to request a new version.

Requirements for the Register of Information

The content requirements for the register are outlined in the ITS, which specifies the mandatory data points. Additionally, the EBA has published further guidance on its website, including the data point model, technical checks, validation rules, and common errors from 2025.