The Register of Information under the EU’s Digital Operational Resilience Act (DORA) isn’t just another checkbox on your compliance list—it’s the backbone of a robust resilience framework. Far from being an optional administrative burden, this registry serves as the definitive record of every digital service your institution relies on, ensuring nothing slips through the cracks.
By establishing a clear, up-to-date inventory of cloud providers, software vendors and third-party platforms, the DORA Registry enables financial entities to demonstrate, at a glance, their operational footprint. In the sections that follow, I’ll explore the registry’s core requirements and reveal why mastering its implementation is critical for safeguarding digital operations and meeting regulatory expectations.
What is the DORA Register of Information?
At its core, the DORA Register of Information is a structured record required under Article 28 of the EU’s Digital Operational Resilience Act (DORA). It mandates that all financial entities maintain a comprehensive inventory of their contractual arrangements with ICT third-party service providers.
But this isn’t a list of vendors or a simple table of contracts. The Register must reflect a detailed and interrelated view of an institution’s digital supply chain—showing how service providers link to critical business functions, where data is processed, how risk tolerances are defined, and how each contractual relationship is managed over time.
This register is not only foundational to regulatory reporting, but also a mirror of an institution’s operational maturity. It demonstrates that an organization knows who it depends on, what those providers do, and how resilience is ensured if something fails.
What the register must include
The required data structure is extensive. The European Supervisory Authorities (ESAs) have outlined specific templates and schemas that institutions must follow. These templates include over 15 interrelated tables that span organizational, contractual, and operational dimensions.
Each table must be linked using consistent identifiers, and all fields—such as contract codes, service types, and jurisdiction references—must conform to strict data dictionaries.
| Category | Description |
| Organizational structure | Legal entities and their internal roles across jurisdictions |
| Business functions | Activities supported by ICT providers, and their criticality ratings |
| Contracts | Contract terms, renewal dates, governing law, and termination conditions |
| ICT service providers | Legal names, LEIs, countries of registration, and subcontractor chains |
| Risk assessments | Risk tolerance thresholds for critical functions and ICT dependencies |
| Financial exposure | Value of services, asset protection levels, and expenditure breakdowns |
| Support relationships | Mapping of support arrangements and how they feed into business continuity |
These categories aren’t optional. They’re part of a schema that financial entities must adhere to when submitting their official DORA Register to supervisors.
Why precision matters
DORA isn’t just a reporting regulation—it’s about operational evidence. The register must be delivered in machine-readable formats, such as XML or CSV, and regulators expect consistency, validation, and internal coherence between tables.
A single misstep—like an invalid service code or missing link between a function and its supporting contract—can cause validation failures and trigger supervisory review. And because the regulation calls for continuous oversight, the register must be kept current throughout the year, not just during an annual submission cycle.
This is where many institutions encounter friction. Even those with robust vendor management systems often struggle to produce a clean, linked, and up-to-date DORA register—because their internal data is fragmented, inconsistent, or out of sync.
The operational impact of maintaining the register
The register isn’t static. It’s a living document that needs to evolve in tandem with vendor relationships, new services, contract renewals, and emerging risks.
Here’s what that looks like in practice: when a contract with a cloud service provider is amended to change the hosting jurisdiction, that update must propagate across multiple records in the register—affecting contract details, service mappings, and criticality thresholds. Similarly, when a function previously deemed “non-critical” becomes central to a new digital offering, it must be reassessed, reclassified, and realigned with updated risk tolerances and third-party dependencies.
This continuous maintenance means that compliance is no longer a quarterly activity—it’s a daily discipline.
| Lifecycle Stage | Activity |
| Initial build | Mapping all ICT contracts and business functions |
| Validation | Ensuring all dependencies and codes align across the register |
| Export and submission | Formatting and submitting reports to national competent authorities |
| Ongoing updates | Adjusting register in response to changes in contracts, providers, etc. |
| Internal review & audit | Preparing reports for internal audit and supervisory follow-ups |
For many, this process stretches teams beyond what manual methods can support.
A smarter way to stay compliant without the spreadsheet sprawl
Dedicated tools like the DORA Registry builder automate data entry, validation logic, relationship tracking, and export-ready formatting from the start. Many competitors feel like spreadsheets: you open a contract, hunt for names, codes, countries, then copy/paste across multiple tabs—slow, error-prone, and repetitive. We aim to change that.
Our contract-centric process uses a single guided form: enter each detail once, and the system intelligently merges and distributes it across all tables and XML/CSV exports while preserving relational logic. The CyberUpgrade DORA Registry mirrors DORA’s structure, supports continuous updates without manual repetition, and fits seamlessly into existing compliance workflows. Legal and compliance teams can build and maintain the register independently—no more juggling tabs or repeated copy/paste, audit-ready from the first entry.
We’re in the development stage but want to reach as many customers as possible, so we’re opening early access as a free trial.
Why the DORA registry is more than compliance
The Register of Information isn’t just a reporting formality—it’s a proxy for how well an institution understands its digital ecosystem. Supervisory authorities use the register to assess whether your organization has a grasp on where its digital risks lie, how they’re being managed, and what would happen in the event of disruption.
In that sense, building the register is like mapping your own resilience blueprint. It shows:
- How business-critical systems are supported by third parties
- Which jurisdictions and subcontractors play roles in service delivery
- Where the weakest contractual protections may exist
- How financial and operational dependencies align with risk appetite
A well-maintained register doesn’t just help with DORA—it supports strategic planning, procurement governance, and incident response.
And that’s the real opportunity: what starts as a regulatory obligation can quickly evolve into a tool for decision-making—if it’s built and maintained with purpose.
Is your institution ready to submit?
Ultimately, the DORA Registry is about clarity. It’s a map of your institution’s operational dependencies, written in a language both your board and your regulator can understand. Done poorly, it’s a collection of mismatched spreadsheets and outdated entries. Done well, it’s a living tool for control, continuity, and confidence.
So ask yourself: does your register show where your real risks live—or is it just another box ticked? If the answer leans toward the latter, now is the time to change course. Because in the world of digital resilience, visibility isn’t optional—it’s everything.
