The European Supervisory Authorities (ESAs) held a joint workshop on the results and learnings from the Register of Information (RoI) dry run exercise run earlier in 2024.

The purpose of this workshop was to provide all financial entities with a view on lessons learned from the exercise, provide guidance on how to populate the RoI and to provide an update on the finalised RoI implementing technical standard (ITS), adopted by the European Commission on 29 November 2024, and what the changes mean for financial entities.

Financial entities who participated in the exercise will already have received feedback on their submission directly from the national competent authority (NCA).

Overview and key takeaways from dry run exercise

Overall, 1039 financial entities took part in the dry run exercise including 39 Irish financial entities. Credit institutions and Insurance and Reinsurance Undertakings represented just over half of the total participants (485).

Of note is that 58% of registers were provided at a consolidated level, bringing the total number of entities covered to almost 3,500.

Over 18,000 functions were reported, with 80% of these being assessed as critical by the financial entities. EY expects the percentage of critical function may change considerably as entities submit their final complete registers in April 2025 here in Ireland, as at the time of the dry run, financial entities may have prioritised gathering information on their critical or important functions and only submitted this information.

The majority of submissions for the dry run were not complete RoIs.

In total, over 25,000 unique contractual arrangements were reported with roughly 10,000 unique third-party providers identified as part of the dry run.

Data quality was of significant concern to the ESAs with only 6.5% of submissions successfully passing all data quality checks.

However, 50% of the remaining submissions passed all but 5 or less of the 116 data quality checks, which indicates that many financial entities are on track in terms of their design of the RoI.

Data quality

The ESAs emphasised the importance of data quality in relation to the RoI, stating that financial entities should be focusing on the RoI instructions and data validation rules to ensure the register is aligned with the expectations of the ESAs. It was also noted that where there is a trade-off between data-quality and completeness, financial entities should prioritise data quality.

Common data quality issues noted in the dry run exercise included the use of incorrect identifiers for financial entities and ICT third party service providers, not using the provided drop-down list values provided, mandatory fields not being populated and date format issues. Financial entities should focus on these areas to ensure their RoI is populated correctly.

Register of Information technical package

The ESAs confirmed that the final technical package which will be used for the “steady-state reporting” will be published in the coming days ahead of the year end.  This will include data point model, validation rules and taxonomies.

A Q&A in relation to the RoI will also be published in January 2025 to explain the inconsistencies between the data point model (DPM) taxonomies and the final ITS instructions.

Throughout the presentation, the ESAs emphasised the importance of reading, understanding and following the DPM and data validation instructions when designing and completing the RoI. Many questions or issues raised by financial entities are answered in these documents.

As part of the updated technical package, the ESAs will provide an updated Excel template for the RoI, which will be aligned with the templates outlined in the ITS and provide an illustrative view to financial entities on the design and fill-in instructions for each data field.

However, importantly, the ESAs were clear in advising financial entities to not use this template, or Excel in general, to build their RoIs as Excel does not provide the interconnectivity that is required for the RoI. The ESAs recommended that financial entities identify the appropriate tooling to build their RoI. It was noted however, that for smaller financial entities, Excel may be a proportionate option to use.

It was also confirmed that the previous ESA-provided “XLS to CSV conversion tool” was a once-off provision for the dry exercise and will not be provided by the ESAs moving forward. The submission of the RoI must still be in the plain CSV format.

RoI data validation process

The ESAs provided an overview of the submission process and data validation checks that will be completed on submissions. Upon submission of the RoI, a two-step data quality assurance process for each submission will be completed, including 3 integration checks and 116 data checks. These focus on the use of the correct naming conventions, correct templates and the use of the correct data types for each submission. Key to this will be the use of and adherence to the provided instructions and data models which have been updated to align with the technical standards.

Lessons learned for the ESAs

As a result of the dry run, the ESAs have also taken on board their own lessons learned from the exercise. In particular, they have reflected on the industry feedback received, considering their opinion on the rejections of the ITS on the RoI which was published on the 15 October 2024. The data model and validation rules have also been updated and published by the ESAs on 15 November 2024 to reflect the learnings and identified issues from the dry run as well as the major changes to the final ITS.

Finalised ITS on the Register of Information

The ESAs provided an overview of the changes to the final ITS on the RoI, including the addition of EUIDs and the removal to maintain expired contracts within the register.

This includes the addition of new data fields to accommodate additional identifiers for ICT third party service providers, such as the European Digital Identifier (EUID).  EUIDs are available to most of the EU-registered companies in the national business registers or in the Business Register Interconnection Systems (BRIS).

However, it was noted that all financial entities must use the Legal Entity Identifier (LEI). If financial entities do not yet have an LEI, they must create this ahead of submission.

The ESAs also noted other updates to the ITS, including the removal of the requirement to maintain expired contracts for five years. While this will not be supervised by the ESAs or NCAs under DORA, financial entities must still operate under their own defined data retention processes.

The ESAs confirmed that work is also underway with regard to the intersection of the DORA RoI and Outsourcing registers. The ESAs are working to review existing Outsourcing guidelines and draft amendments or republications as needed.

What is next?

The ESAs confirmed today that the technical package to support the development of financial entities RoIs will be published in December 2024.

It was also confirmed earlier this month that the first submission of the RoIs to the ESAs will take place at the end of April 2025, reporting on data as at the end of March 2025.

In line with this, each NCA will communicate timelines for submission of the RoI to the NCA. In Ireland, the Central Bank of Ireland (CBI) has confirmed that the submission date will be in the first week of April 2025.

Ahead of this, financial entities should be working to design, build and populate their RoIs in line with the DPM, validation rules and instructions provided by the ESAs to ensure they are ready to submit their RoI in line with these timelines.

Annual reporting of the RoIs will be required from 2026 onwards.  The reference date will be 31 December from the previous year with a 31 March remittance deadline within the current year in question.