The Digital Operational Resilience Act (DORA) requires the use of function identifiers (F keys) in schema 06.01, which seems simple at first — but quickly becomes complex.
Managing these identifiers properly is critical for maintaining consistency across linked schemas like 02.02.
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Understanding function identifiers (F keys)
In schema 06.01, each business function must be assigned a unique F key (e.g., F1, F2, F3). But the assignment isn't just based on the function name — it's tied to:
- The specific licensed activity the financial entity performs
- The ICT services supporting that activity or function
As a result, every unique combination of function, activity, and ICT service may require a different identifier.
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The problem: integration with schema 02.02
Schema 02.02 connects these F keys to contractual arrangements and ICT services. If something changes in 06.01 — for example, removing or reordering functions — it creates serious risks:
- Renumbering breaks mappings: If you remove an entry and renumber F1 to F2, existing mappings in 02.02 will no longer align
- Manual tracking gets risky: Especially with Excel, keeping everything aligned becomes error-prone and time-consuming
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Our recommendation: incremental numbering
To avoid breaking connections across schemas, adopt persistent and incremental F numbering:
- If you remove a function, don’t reuse or renumber existing F identifiers
- Assign new F keys sequentially (e.g., F101, F102, F103…)
- Maintain a consistent mapping between function entries and their linked records
This keeps schema 02.02 aligned even as your business structure evolves.
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Conclusion
F identifiers may look simple — but under the hood, they connect critical parts of your DORA reporting.
Avoid renumbering. Instead, use persistent, incrementing IDs to prevent downstream errors, reduce rework, and maintain compliance across linked templates.
A structured approach to function mapping doesn’t just ensure accuracy — it also saves time and protects your reporting integrity.
Originally published on DORA Solutions Insights.