Building the DORA Register of Information: From Vendor Spreadsheet to Regulatory Data Product

DORA · Register of Inform

Why your vendor list doesn't qualify. The RoI's structure is fixed by an implementing regulation, CIR (EU) 2024/2956, which prescribes interlinked templates with mandatory fields and controlled vocabularies. Every ICT provider must be identified by LEI (legal entity identifier) — not by whatever name accounts payable uses. Every arrangement needs a unique reference, a service-type taxonomy code, the countries where the service is provided and where data is stored and processed, contractual start and end dates, notice periods, a substitutability assessment, and — the field that breaks most first attempts — the full sub-contracting chain beneath each service supporting a critical function. Submissions are machine-validated; regulators across Member States rejected a substantial share of first-round files for structural errors alone. A flat vendor list simply cannot represent this: the RoI is a relational model (entities → arrangements → services → functions → subcontractors), and it wants to live in a system, not a workbook.

The hard fields are hard for a reason. Three deserve special attention. Criticality mapping: each arrangement must state whether it supports a critical or important function, which presupposes you have formally designated those functions — a governance decision, not a data entry. Substitutability: you must assess how easily each critical provider could be replaced, which forces an honest conversation about exit strategies that Article 28(7) separately requires. Sub-processor chains: your cloud provider's dependencies become your reporting obligation, so Article 30 contractual rights to sub-contracting transparency stop being boilerplate and start being your data supply chain.

A build sequence that works. Start with discovery reconciliation: merge procurement records, accounts-payable data, contract repositories, and your asset register, then dedupe — the deltas between those sources are themselves findings. Second, enrich: obtain LEIs (many suppliers must be chased to register for one), classify services against the prescribed taxonomy, and extract contract dates and notice periods from the actual agreements rather than memory. Third, map to functions: link every arrangement to the business functions it supports, flagging the critical ones. Fourth, chase the chains: issue sub-processor disclosure requests to every critical-function provider, contractually anchored in Article 30(2)(i). Fifth, validate early against your regulator's submission tooling — do not discover schema errors in submission week.

Treat it as a product, not a filing. The entities that suffered least made one design decision early: the RoI is a maintained data product with an owner, a change process, and quality metrics — refreshed continuously by procurement and vendor-management workflows, with the annual submission as a mere export. New ICT contracts cannot be signed without the fields the register needs; renewals trigger re-validation; offboarding closes arrangements with end dates. This is also the only economically sane approach, because the register feeds obligations well beyond reporting: Article 29 concentration-risk assessments are queries over it ("which critical functions share a single provider or region?"), exit-strategy planning starts from its substitutability column, and incident response uses it to answer "what do we run on the provider that just went down?"

What it will reveal — and that's the point. A truthful register usually surprises its own organisation: more ICT arrangements than anyone believed, a heavier concentration on one or two hyperscalers than the board has acknowledged, legacy contracts missing Article 30 provisions, and critical functions resting on providers nobody formally assessed. Uncomfortable, but that discomfort is the regulation working as intended — the RoI exists precisely to make systemic dependency visible, to your board before your supervisor.

The register rewards the same virtues as any data product: a single source of truth, controlled inputs, versioned outputs, and someone accountable for quality. Build it that way and DORA's most tedious obligation becomes the most useful map of your operational reality you have ever had. Build it as an annual spreadsheet scramble and you will rebuild it every year — under more supervisory attention each time.