Many organizations are using Excel to set up and manage their DORA Register of Information (RoI) but Excel simply isn’t built for this task.
The problem lies in the complexity of relational data. DORA expects strict links between entities, contracts, services, and providers. Excel offers none of the built-in safeguards to maintain this structure.
01
Excel’s fundamental limitations
The DORA register consists of interlinked tables for example, contracts must link to service providers, and business functions must link to ICT services. In this structure, referential integrity is critical. If one row refers to a vendor, that vendor must exist elsewhere in the register and stay consistent.
With Excel, it’s all too easy to:
- Reference non-existent vendors
- Paste data in the wrong sheet
- Forget to update linked rows after a change
These mistakes introduce hidden errors and compliance risks.
02
The importance of referential integrity
Under DORA, the RoI includes multiple templates, each representing a specific domain (e.g., contracts, functions, providers). These tables must link precisely.
If a contract points to a provider ID, that provider must exist and match the expected format. In a recent ESA pilot, most institutions failed validation because of issues like:
- Missing or mismatched IDs
- Invalid entity codes
- Incomplete fields
Only a small minority passed the validation phase without serious corrections.
03
Why Excel isn’t a relational database
Excel is a spreadsheet, not a database. It doesn’t enforce the logic required for relational models. Here’s why that’s a problem:
- No built-in referential checks: Excel can’t guarantee that IDs used across sheets are valid or unique
- Data redundancy: The same info is often copied into multiple tabs, which go out of sync
- No automated rules: Excel relies on user diligence, and humans make mistakes
A single broken link or deleted row can cascade into compliance errors.
04
Human error and growing complexity
As your register grows and more users contribute, the chance of error increases. Manual updates, edits across tabs, and duplicated data mean even the most organized Excel file will drift from accuracy over time.
06
Avoiding a false sense of security
Because Excel feels familiar, it creates the illusion of control. But under the surface, you’re working without guardrails. Excel doesn’t stop you from making errors, and you may not spot them until it’s too late.
07
Conclusion
The DORA Register of Information demands relational integrity and high data quality.
Excel lacks the tools to enforce that structure. While it may be useful for early drafts, it’s not a viable solution for ongoing compliance.
To meet DORA's standards and reduce risk:
- Use tools that are purpose-built for relational data
- Automate integrity checks and updates
- Eliminate manual processes wherever possible
08
Stay informed
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Originally published on DORA Solutions Insights.