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HodeiShield®

The DORA register of information, without starting from the spreadsheet

By HodeitekPublished

If you are the CISO of a financial entity and you are asked for the DORA register of information without a third-party engineering team, this guide gives you the order of work and what to decide before opening any template.

What exactly you are asked for

DORA is Regulation (EU) 2022/2554 and it has applied since 17 January 2025. Its Article 28(3) requires the financial entity to maintain and update a register of information on all contractual arrangements for the use of ICT services provided by third-party providers.

The format is not improvised: Commission Implementing Regulation (EU) 2024/2956 sets the standard templates of the register. There are 15 templates, which is why the register is best treated as a data set and not as a document.

Where to start on a Monday

Before filling in anything, order what you already have. Four decisions avoid most of the rework.

  • List every contract where a third party provides an ICT service, not only the technology ones: the payroll provider or the document-custody provider too.
  • Decide who owns each contract. Without an owner, nobody updates the data.
  • Note each provider's LEI and jurisdiction. These fields are repeated across several templates.
  • Record in the same place whether an exit plan and an audit right exist, two of the clauses Article 30 asks for in contracts.
ILLUSTRATIVE

What the clause check looks like

Three invented providers, to show what data is asked per contract. They are not real entities nor any customer's data.

Illustrative example: Article 30 clauses per provider
ProviderServiceExit planAudit right
Provider ACloud hostingYesYes
Provider BPayment gatewayYesNo
Provider CDocument custodyNoNo
ILLUSTRATIVE. Synthetic data. In this example an exit plan exists in 2 of 3 contracts and an audit right in 1 of 3.

What HodeiShield does and what it does not

HodeiShield keeps suppliers, contracts and concentration in one register and can generate the register of information as an xBRL-CSV package with the structure of the 15 templates. It records LEI and jurisdiction per provider and tracks the exit plan and the audit right of Article 30.

This is a partial capability: the exporter is still being completed. It does not file anything with the supervisor and does not replace legal review. Filing through the official channel stays with the entity.

Sources

  1. Regulation (EU) 2022/2554 (DORA), Articles 28 and 30, on EUR-Lex (opens in a new tab)
  2. Implementing Regulation (EU) 2024/2956, register templates, on EUR-Lex (opens in a new tab)

See the register with your own suppliers

In a demo we walk through the ICT provider register, the clauses and the sample package with sample data. A person at Hodeitek answers you.

Request a demo