The Digital Operational Resilience Act (DORA) represents a significant shift in how financial organizations manage digital risks. For SMEs in the financial sector, this isn't just another compliance checkbox — it's a framework that calls for a fundamental rethink of digital operational resilience.
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What is the DORA register of information and why it matters
The register of information is central to DORA’s third-party risk management framework. It’s a standardized system that captures key data about your ICT provider landscape, offering clarity into your digital supply chain.
According to the European Commission's implementing regulation, the register serves three critical purposes:
- Supports internal ICT risk management
- Enables effective regulatory supervision
- Contributes to EU-wide oversight of critical ICT providers
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The real challenge: beyond simple compliance
Many organizations treat DORA — and the register of information — as an administrative task. This leads to shortcuts:
- Hiring consultants for one-time fixes
- Relying solely on templates from regulators
- Submitting minimal data just to meet the deadline
But the register is intended to be a risk management instrument. If done right, it offers strategic insight into your digital dependencies and vulnerabilities.
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Three essential steps to an effective register of information
1. Map your business functions
The starting point isn’t your IT providers — it’s understanding your own organization. DORA requires that you identify business functions and assess whether they are critical or important based on:
- Operational impact: Would disruption affect service continuity?
- Financial impact: Would it cause material losses or missed revenue?
- Compliance impact: Would it compromise your regulatory obligations?
This work likely overlaps with your business continuity planning — don’t reinvent the wheel.
2. Map your ICT provider landscape
Next, identify the ICT service providers you contract with. This step can be time-consuming initially, but it lays the groundwork for accurate risk mapping.
Look carefully at all contracts that contain ICT components — and make sure none are missed.
3. Make the connections
Link your ICT services to the business functions they support. This helps reveal:
- Which third parties pose the greatest risk
- Where you need stronger controls or exit plans
- Where redundancies may be necessary
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Benefits beyond compliance
Done properly, the register gives you:
- Valuable insights: A clear view of your operations and digital supply chain in one place
- Regulatory readiness: Demonstrates to supervisors that you understand your ICT landscape and manage risks
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Common pitfalls
The biggest mistake? Treating the register as a procurement or legal task instead of a risk management activity.
When ownership is fragmented — between legal, vendor management, and procurement — the result is often a contract repository, not a risk register.
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Taking action
As a board or executive team, ensure DORA implementation is approached strategically, not tactically. That means:
- Recognizing the strategic value of a well-built register
- Allocating proper resources to map your functions and ICT dependencies
- Embedding regular updates into your operational cycle
DORA is an opportunity to enhance resilience — but only if you treat it as more than a checkbox.
Originally published on DORA Solutions Insights.