--- title: "EBA Q&A 2025_7362 — Q&A — Register of Information Taxonomy reporting [Rejected question]" shortTitle: "EBA Q&A 2025_7362 — Q&A — Register of Information Taxonomy reporting [Rejected question]" answer_id: EBA_QA_2025_7362 status: "Rejected question" type: qa instrument_type: qa authority: EBA binding: false binding_character: non_binding legal_status: withdrawn regulation: "DORA" dora_level3: true mica_level2: false legal_basis: "Article 28(3) DORA" date: 5 May 2025 source_link: https://www.eba.europa.eu/single-rule-book-qa/qna/view/publicId/2025_7362 lifecycle: "Rejected question" text_version: "EBA Q&A register, 5 May 2025" source_url: "https://www.eba.europa.eu/single-rule-book-qa/qna/view/publicId/2025_7362" check_status: matched verified: true last_checked: 2026-10-26 checked_against: "the EBA publication" source: prepared_by: "not stated in the document" published_by: "EBA" published_in: "EBA Single Rulebook Q&A tool" evidence: prepared_by: "Other" locator: "EBA Q&A register entry 2025_7362: no answer; the register names only the 'Type of submitter'" document_type: "qa_question" legal_nature: "not_legislation" addressees: "not stated in the document" dates: published_on: "2025-05-05" question_submitted_on: "2025-02-28" locators: published_on: "EBA Q&A register entry 2025_7362, field 'Rejected publishing date'" question_submitted_on: "EBA Q&A register entry 2025_7362, field 'Submission date'" lifecycle_label: "Rejected question" --- **Question published in the EBA Q&A tool · no answer · not legislation · published 5 May 2025 [Rejected question]** *Rejected question · EBA Q&A register, 5 May 2025 · Checked against the EBA publication on 26 Oct 2026 · [Official source](https://www.eba.europa.eu/single-rule-book-qa/qna/view/publicId/2025_7362)* | | | |---|---| | **Full title** | EBA Q&A 2025_7362 — Q&A — Register of Information Taxonomy reporting \[Rejected question\] | | **Prepared by** | Not stated in the document | | **Published by** | EBA, in the EBA Single Rulebook Q&A tool | | **Reference** | EBA_QA_2025_7362 | | **Document type** | Q&A | | **Legal nature** | No answer · not legislation | | **Addressees** | Not stated in the document | | **Dates** | Published 5 May 2025; question submitted 28 February 2025 | | **Legal basis** | [Article 28(3)](https://www.headlesslaw.com/dora/articles/28) DORA | | **Related instruments** | None recorded | | **Text on this page** | Word for word — the full text of the EBA publication | **Register of Information Taxonomy reporting vs ITS on Register of Information** ### Question In the industry workshop of 18 of December 2024, which was a summary of Dry Run, it was stated that the reporting taxonomy provided shall be used for the reporting , while the current DORA 4.0 validation rules does not follow the instructions provided in the ROI ITS. We kindly ask you to confirm if the reporting shall follow the DORA 4.0 validation rules despite the mismatch with the ROI ITS. Differences between the law and the taxonomy: Requirement in Law Requirement in Taxonomy Additional question B\_01\_01\_0010 stated as non-nullable, but is mentioned as nullable in "LEI - EUID checks VR-2" B\_01\_02\_0010 stated as non-nullable, but is mentioned as nullable in "LEI - EUID checks VR-12" B\_02.03 does not include an extra column c0030 b\_02.03 has a column c0030, that is required to be filled out What is the extra column used for? B\_03.01 does not include an extra column c0030 b\_03.01 has a column c0030, that is required to be filled out What is the extra column used for? B\_03.03 does not include an extra column c0031 b\_03.03 has a column c0031, that is required to be filled out What is the extra column used for? B\_04.01 clarifies that column c0040 is only mandatory if the financial entity making use of the ICT service(s) is a branch of a financial entity (B\_04.01.0030) B\_04.01 column c0040 is mandatory. Which also requires at least 1 branch in B\_01.03. What should be reported if a reporting entity does not have any branches? Should both B\_01.03 and B\_04.01 be empty. Or? B\_05.01 c0030 & c0040 is optional B\_05.01 c0030 & c0040 is required when c0070 = Legal person, excluding individual acting in a business capacity B\_05.01 c0110 is mandatory if the ICT-third party service provider is not the ultimate parent undertaking B\_05\_01\_0110 is mandatory all the time according to the DPM B\_05.02 column c0060 & c0070 is mandatory, but not applicable for rank 1. An empty value should be reported if rank = 1 B\_05.02 column c0060 & c0070 is always required. What should be reported in c0060 & c0070 if the rank = 1? B\_01\_01\_0050 is mandatory in case of reporting B\_01\_01\_0050 is always mandatory B\_01\_01\_0060 is mandatory in case of reporting B\_01\_01\_0060 is always mandatory B\_01\_02\_0060 is mandatory B\_01\_02\_0060 is optional in DPM B\_02\_01\_0030 is mandatory B\_02\_01\_0030 is optional in DPM B\_02\_02\_0040 is mandatory B\_02\_02\_0040 is optional in DPM B\_02\_02\_0130 is mandatory if the ICT service is supporting a critical or important function B\_02\_02\_0130 is optional in DPM B\_02\_02\_0140 is mandatory if the ICT service is supporting a critical or important function B\_02\_02\_0140 is optional in DPM B\_02.02.0150 is mandatory if Yes is reported in c0140 B\_02.02.0150 is mandatory in DPM B\_02.02.0160 is mandatory if the ICT service is based on or foresees data processing B\_02.02.0160 is mandatory in DPM Additional to the question above: If changes will be made to the Taxonomy, when will these be made available? Do you foresee to apply changes to solve the aforementioned mismatch? If so, can you please share when this is expected to be done? If the current Taxonomy, DORA 4.0, must be followed for reporting, can we expect that all local authorities are required to accept the Register of Informations in the format aligned with the Taxonomy? We have experienced differences while doing a mock exercise to submit the reports to local authorities from the reporting technical package. To our knowledge, these discrepancies shall not exist and the national authorities to which entities have to report to are required to accept files that follow the reporting technical package. In this scenario, what actions can we expect to be taken? ### Background We provide a solution that helps clients in the financial European environment comply with DORA requirements. We are currently preparing for the submission of Register of Information for many of our clients. In the process we have noticed differences between the Reporting framework 4.0 for DORA and the Commission Implementing Regulation (EU) 2024/2956 of 29 November 2024 laying down implementing technical standards for the application of Regulation (EU) 2022/2554 of the European Parliament and of the Council with regard to standard templates for the register of information (going forward ROI ITS) *** ### Answer This question has been rejected because the matter it refers to has been answered in the Frequently Asked Questions on the Reporting of registers of information under DORA. *** **Source:** [EBA original document](https://www.eba.europa.eu/single-rule-book-qa/qna/view/publicId/2025_7362) ## Related Level 1 articles - [Article 28 — General principles](../../../articles/28.md)