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DORA

DORA ICT register template

DORA ICT register template guidance: provider inventory, contracts, criticality, subcontractors, concentration risk, exit plans and evidence fields.

Direct answer

A DORA ICT register template should include each ICT provider, service, contract owner, criticality, data location, subcontractors, exit plan, incident contact, renewal date, risk assessment and supporting evidence. The register should be usable for governance, audit, customer review and regulatory reporting.

What should a DORA ICT register template include?

A DORA ICT register template should include each ICT provider, service, contract owner, criticality, data location, subcontractors, exit plan, incident contact, renewal date, risk assessment and supporting evidence. The register should be usable for governance, audit, customer review and regulatory reporting.

  • Provider identity
  • Criticality
  • Exit and incident data
Main artifactICT third-party register
Best ownerRisk, compliance or operations
Review cadenceAt onboarding, renewal and material service change
Source: ESMA DORA guidanceReviewed:
DORA ICT register templateESMA DORA guidance

A DORA ICT register template should include each ICT provider, service, contract owner, criticality, data location, subcontractors, exit plan, incident contact, renewal date, risk assessment and supporting evidence. The register should be usable for governance, audit, customer review and regulatory reporting.

OngoingProvider register maintenance

Update whenever an ICT provider, contract, criticality or subcontractor changes.

Source: ESMA DORA guidance

DORA ICT register template checklist

Action checklist
Provider identity

Record legal name, service, contract owner and business process.

Criticality

Assess service criticality, dependencies and concentration risk.

Exit and incident data

Keep exit plan, incident contact, SLA and renewal date.

Key deadlines

DateRequirementSource
OngoingProvider register maintenanceUpdate whenever an ICT provider, contract, criticality or subcontractor changes.ESMA DORA guidance

30/60/90-day action plan

First 30 days

Confirm scope and assign an owner

Evidence needed: Applicability note, business owner, systems or product list, and source links.

DORA ICT register

Days 31-60

Close the evidence gaps

Evidence needed: Policies, supplier records, data maps, technical notes, training records, or process owners.

DORA ICT register

Days 61-90

Prepare for audit or customer review

Evidence needed: Versioned compliance file, action log, exception register, and next review date.

DORA ICT register

Evidence to retain

Applicability decision

Shows whether a DORA ICT register applies and why the SME made that decision.

Retain: Scope memo, trigger criteria, country notes, owner approval, and review date.

Action owner list

Regulators and enterprise customers expect named accountability, not generic intent.

Retain: Owner, backup owner, due date, status, and unresolved blocker notes.

Evidence folder

The fastest way to answer customer due diligence is a single audit-ready evidence file.

Retain: Policies, screenshots, registers, exports, supplier responses, and training records.

SME questions answered

Is a vendor list enough for DORA?

No. DORA needs an ICT register with service criticality, contracts, risks, subcontractors, incidents and exit planning.

Who should own the DORA ICT register?

Risk or compliance should govern it, but procurement, IT and service owners must maintain the underlying facts.

Turn this guide into a tracked action plan

Start with the Regulation Checker, save the result, and import the action plan into your EuroComply dashboard when you are ready to assign owners.

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Informational only. This page is not legal advice and does not replace a qualified legal review of your business, systems, products or employment practices.