Guidance for correction of most frequent issues identified in the submitted Registers of Information under DORA

Following the end of their user acceptance testing (UAT) of the reception of the Register of Information (RoI), the ESAs have published ‘Observations from testing of RoI reporting to the ESAs. Key common issues identified’, a document listing the key common issues identified during this phase.

Given that the CSSF is receiving the RoI from financial entities under its supervision from 1 April on, the CSSF also compiled a guide aiming at assisting financial entities in resolving issues detected during the validation checks of the submitted RoI by the CSSF and the ESAs.

This guide shall be read in conjunction with the above ESA observations.

The CSSF guide is not intended to be exhaustive but covers the most common issues encountered during the validation checks of the received registers. It is a living document which will be updated on a regular basis. The CSSF advises financial entities to consult this guide before contacting our helpdesk.

In addition, the CSSF would like to inform the few entities who have not yet submitted their RoI, that they are still required to do so as soon as possible. In this context, the CSSF raises the attention to a guidance document published on 7 April and updated today. This document clarifies whether the submission of a RoI by Luxembourg-based financial entities subject to DORA and supervised by the CSSF or the ECB is expected to be sent to the CSSF on a consolidated or individual basis, or to another competent authority as part of the consolidated register of its parent company. We advise financial entities to consult this document in case of doubt.