Recently, we reported in our news alert that the Dutch Authority for the Financial Markets ("AFM") will in February 2025 require financial institutions under its supervision to submit their DORA registers. In a similar vein, the Dutch Central Bank ("DNB") has now announced its intention to request the DORA registers from financial institutions in April 2025.
In its announcement published on 23 January 2025, DNB provided additional information that might be useful to financial institutions still completing the DORA registers. Among others, it draws attention to the website made available by the European Supervisory Authorities ("ESAs") which includes information about the validation rules used, as well as a visual representation of the data model.
DNB stresses that financial institutions who fail to complete the DORA register in time are urged to prioritise the quality of the provided data over the completeness of the ICT agreements included in the DORA register. Further, DNB announced that it is accommodating companies that are unable to achieve timely implementation of the required standard (xBRL-CSV format). These financial institutions can opt to report the DORA register using a standardised Excel template, after which DNB will ensure its conversion to the required standard.
Lastly, DNB's announcement contains further explanations about the consolidation level at which it shall request the DORA register:
- Financial institutions for which DNB is the competent supervisor and who are not part of a group of financial institutions shall submit the DORA register at the level of the individual licenced entity. The same applies to financial institutions for which DNB is the competent supervisor and which are part of a group of financial institutions where the parent is registered outside the European Union, and there is no European sub-consolidation.
- Financial institutions for which DNB is the competent supervisor but who are part of a group of financial institutions where DNB also supervises the parent company shall deliver the DORA register at the highest level of consolidation as far as it concerns institutions within DNB's supervisory mandate. If the parent company falls under the supervision of another European financial supervisor, the DORA register should be submitted to that supervisor at the highest level of consolidation for the licensees that fall within that supervisor's supervisory mandate.
- Financial institutions for which DNB is the competent supervisor and who are part of a group of financial institutions and where the parent is not subject to European financial supervision at the consolidated level, shall submit the DORA register at the level of the individual licenced entity.
DNB's announcement can be found here (available in Dutch only).
Contact
Should you require any assistance with the preparation of the DORA register for your organisation, please do not hesitate to reach out to us.
