The European Supervisory Authorities (ESAs) comprising of the European Banking Authority (EBA), European Insurance and Occupational Pensions Authority (EIOPA), and European Securities and Markets Authority (ESMA) have jointly published a summary report on the key findings of the 2024 ESAs Dry Run exercise. Launched in April 2024, the dry run tested the reporting processes for the registers of information (RoI) under the Digital Operational Resilience Act (DORA). Findings indicate to the ESAs that having registers of “sufficient quality” in 2025 is “not out of reach”.
When DORA comes into scope on 17 January 2025, in-scope financial entities will be required to keep a comprehensive RoI of their contractual agreements with ICT third-party service providers. The dry run exercise was launched to help these entities develop their RoI in accordance to the requirements set out in the implementing technical standards (ITS) and ready them for reporting from 2025.
In total, 1,039 financial entities participated in the exercise. Only registers that passed data integration checks were analysed, of which there were 947. Of these, 6.5 per cent “successfully passed all data quality checks” and 50 per cent of the remaining registers “failed less than five data quality checks”. Missing mandatory information was the most frequently occurring quality check failure, making up 86 per cent of all data errors.
Best is not enough
The dry run exercise was conducted on a “best efforts” basis. Financial entities were allowed to submit partial registers with mandatory data fields missing. This would not be possible once official reporting begins in 2025. The ESAs encourage in-scope entities to “familiarise themselves as much as possible with and follow all instructions provided in the ITS as well as practical clarifications provided in the FAQ for the dry run exercise”. It is important that these entities “continue identifying and integrating the missing data into their RoI, so they are able to submit full registers to their competent authorities and then the ESAs”.
