Register of Information
Under DORA, financial institutions must maintain an information register for all contractual agreements with third-party ICT service providers at entity, sub-consolidated and consolidated level. The information register must be shared annually with the national supervisor, who will then share it with the European supervisors (EBA, EIOPA and ESMA).
We can also use the information for our (risk-based) supervision of the financial entities covered by DORA.
Consolidation level
Depending on the situation that applies to your company, you must provide the register of information at the following level of consolidation:- At the level of the financial entity, where the financial entity is not part of a group of financial entities.
- At the level of the financial entity, where the financial entity is part of a group of financial entities and the parent undertaking(s) is/are located outside the European Union.
- At the highest level of consolidation in the European Union, where the financial entity is part of a group of financial entities and the AFM has supervisory responsibility pursuant to the Union acts referred to in Article 46 of DORA.
Financial entities for which we are the competent supervisory authority and which are part of a group of financial entities in which the parent company at the consolidated level does not fall under the supervision of another competent authority in the European Union must submit the register of information at the level of the individual financial entity.
Submitting in xBRL-CSV
You can only submit your information register to us in xBRL-CSV, not in a standard Excel file. We facilitated the conversion to xBRL-CSV in 2025 as a one-time additional service to support companies in submitting their information registers.If you use a converter to convert your information register to xBRL-CSV, it is important to note the following points:
- Not all XBRL converters are suitable for information registers. It is important that the converter is capable of converting your register to xBRL-CSV (not iXBRL!);
- Check whether the converter supports the EBA taxonomy;
- The xBRL-CSV file must meet several requirements. Examples of the file's intended appearance can be found on the EBA website.
Furthermore, we recommend using tools that perform thorough data quality checks immediately. Additionally, we recommend validating what the provider does with the data.
Procedures at ESAs
The European Banking Authority (EBA) checks whether the file meets all requirements. If this reveals any errors, we will relay the EBA's feedback to the company via the AFM Portal. The reporting obligation will be reopened once the feedback has been uploaded.
From March 2026, feedback will normally be available in the AFM Portal within one business day; in exceptional cases, this may take two days. If it takes longer, please contact dora@afm.nl.
If you resubmit the information register, it is important that the file has a different name than your previous submissions. You can do this by adjusting the last digits of the file name (timestamp).
Questions and answers about the register of information
Below are several questions and answers from the AFM about the register of information . We also have a document with more detailed questions and answers (pdf, 300 kB) following a Q&A session. The ESAs themselves have also published information about the requests and a document with Q&As.
Learn more
The AFM regularly communicates about relevant developments concerning DORA. More information about DORA can be found at our webpages on DORA.
Last modified: March 12, 2026