When a group entity purchases ICT services and provides them to your financial entity, your reporting approach depends entirely on whether you report individually or at consolidated level. This distinction fundamentally changes how you structure your register of information.
01
The problem: same setup, different reporting
Consider this common scenario: Group Holding owns 100% of Financial Entity. Group Holding contracts with External Cloud Provider for cloud infrastructure services and makes these services available to Financial Entity.
How do you report this arrangement in your register of information? The answer depends on your reporting level.
02
Individual reporting: Group Holding outside reporting scope
When Financial Entity reports individually, Group Holding falls outside your organization perspective but is included in your ICT provider landscape. This distinction shapes how you populate templates across both perspectives.
Your organization perspective (templates B_01 and B_02)
Template B_01.02 contains only Financial Entity. Group Holding is not included because individual reporting captures only the reporting entity itself, as stated in FAQ Question 101.
Template B_02.01 lists one contractual arrangement: the contract between Financial Entity and Group Holding. This is the only direct contract relevant to Financial Entity.
Template B_02.03 remains empty. According to the instructions for B_02.03, this template links intra-group contractual arrangements only when the intra-group provider appears in template B_01.02. Since Group Holding is not in B_01.02, no linking occurs here.
ICT provider landscape (templates B_05)
Template B_05.01 lists Group Holding as an ICT service provider alongside the external provider:
- Group Holding (as intra-group service provider at rank 1)
- External Cloud Provider (as subcontractor at rank 2)
- Ultimate parent undertakings:
- For Group Holding: if Group Holding is itself the ultimate parent, its own identification code is repeated in the ultimate parent fields per FAQ Question 99
- For External Cloud Provider: its ultimate parent undertaking
Group Holding appears in B_05.01 because it falls outside the organization scope defined in B_01.02. From the ICT landscape perspective, Group Holding is treated as an ICT service provider.
Template B_05.02 shows the supply chain structure:
- Group Holding: rank 1 (direct provider to Financial Entity per Article 1 ITS)
- External Cloud Provider: rank 2 (subcontractor to Group Holding per Article 2 ITS)
The contract between Group Holding and External Cloud Provider does not appear in template B_02.01 under this interpretation, as Group Holding falls outside the B_01.02 scope.
03
Consolidated reporting: Group Holding inside reporting scope
When Group Holding reports at consolidated level on behalf of Financial Entity, the reporting structure changes completely. Group Holding now falls inside your organization perspective and moves out of your ICT provider landscape. This fundamental shift reverses how you populate templates across both perspectives.
Your organization perspective (templates B_01 and B_02)
Template B_01.02 now contains both Group Holding and Financial Entity, showing their parent-subsidiary relationship via field B_01.02.0060.
Template B_02.01 includes two contractual arrangements:
- Contract between Financial Entity and Group Holding
- Contract between Group Holding and External Cloud Provider
Both contracts appear in B_02.01 because FAQ Question 74 explicitly states that both the intra-group contract and the external contract should be reported.
Template B_02.03 links these two contracts:
- B_02.03.0010: Contract reference Financial Entity ↔ Group Holding
- B_02.03.0020: Contract reference Group Holding ↔ External Cloud Provider
This linking enables traceability of how ICT services flow through the group structure, as explained in FAQ Question 89.
ICT provider landscape (templates B_05)
Template B_05.01 now lists only the external provider:
- External Cloud Provider (as subcontractor at rank 2)
- Ultimate parent undertaking of External Cloud Provider
Group Holding no longer appears in B_05.01 because it is now part of the reporting organization itself (included in B_01.02). The shift from individual to consolidated reporting moves Group Holding from the ICT landscape perspective (B_05.01) to the organization structure perspective (B_01.02).
Template B_05.02 shows a simplified supply chain structure:
- External Cloud Provider: rank 1 (now the direct provider to the consolidated group)
The ranking changes because Group Holding is no longer counted as an ICT provider in the supply chain. External Cloud Provider becomes rank 1 as it is the direct external provider to the reporting organization.
04
Key insight: B_01.02 determines the perspective shift
The presence or absence of Group Holding in template B_01.02 determines a fundamental shift in how you view your organization:
When Group Holding is not in B_01.02 (individual reporting), Group Holding is treated as an ICT service provider in the ICT landscape (B_05.01). You report only your direct contract in B_02.01 and track Group Holding as rank 1 in the supply chain through B_05.02.
When Group Holding is in B_01.02 (consolidated reporting), Group Holding becomes part of your organization structure and no longer appears in B_05.01. You report both the internal arrangement and the external contract in B_02.01, link them via B_02.03, and track only External Cloud Provider in B_05.01 as rank 1.
The critical shift: Group Holding moves from being an ICT supplier (outside organizational scope) to being part of the organization itself (inside organizational scope).
This distinction follows from the Article 1 definition of direct ICT third-party service provider and the consolidation instructions in template B_01.02.
05
Where to find official guidance
The reporting requirements for intra-group arrangements are specified in:
- Article 1 and 2 of the ITS on registers of information (Regulation EU 2024/2956)
- Instructions for templates B_01.02, B_02.01, B_02.03, and B_05.02 in Annex I of the ITS
- FAQ Questions 73, 74, 89, 101, and 102 in the updated DORA RoI FAQ document
Access the latest technical package and FAQ updates through the European Supervisory Authorities reporting portal.
Originally published on DORA Solutions Insights.