The Digital Operational Resilience Act (DORA) requires financial entities to report detailed contractual information about ICT third-party service providers starting January 2025.
In a recent voluntary dry run exercise conducted by the European Supervisory Authorities (ESAs), many institutions learned a hard truth: Excel is no longer enough to meet these reporting demands.
01
Key findings from the ESA dry run
1. High error rates
Out of 1,039 participating financial entities:
- Only 6.5% passed all data quality checks
- A staggering 93.5% had at least one error
This clearly highlights the risks of manual processes and reliance on spreadsheets.
2. Missing mandatory fields
More than 86% of all data errors were due to missing mandatory fields, including:
- Identification codes for ICT third-party providers
- Details on ICT services and contractual arrangements
While the dry run allowed partial submissions, final reporting will require complete and validated data.
3. Complexity will increase
The dry run included optional fields. From 2025 onward, all fields will be mandatory, significantly increasing reporting complexity.
02
Why Excel falls short
Excel may seem familiar and flexible, but it introduces several compliance risks:
- Human error: Managing complex data manually is prone to mistakes
- Validation gaps: Excel doesn’t enforce advanced data validation like a real data point model (DPM)
- Scalability issues: Excel struggles with large, structured datasets and slows down reporting workflows
03
The solution: robust tooling
To meet DORA’s demanding requirements, financial entities should implement automated, purpose-built tools that:
- Ensure data accuracy and completeness
- Streamline reporting workflows
- Validate submissions against regulatory technical standards
Institutions adopting the right tools won’t just comply — they’ll improve their overall ICT risk management capabilities.
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Final thoughts
The ESA dry run sends a clear message: Excel isn’t sustainable for DORA compliance.
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Originally published on DORA Solutions Insights.