Since the Digital Operational Resilience Act (DORA) became fully applicable across the European Union in January 2025, digital resilience has moved from being a strategic objective to a binding regulatory requirement. In 2026, fintech companies are no longer in preparation mode — they are operating under active supervisory scrutiny.
One of the most underestimated yet operationally demanding components of DORA is the Register of Information (RoI). While it may initially appear to be a structured inventory of ICT suppliers, its practical implementation reveals a much deeper layer of legal, technical, and governance complexity.
The real question for fintechs today is not whether a Register of Information exists — but whether it is robust enough to withstand regulatory review.
The regulatory foundation: What DORA actually requires
Under Regulation (EU) 2022/2554, financial entities must maintain a comprehensive and up-to-date register of all contractual arrangements with ICT third-party service providers. This includes not only cloud providers and core infrastructure vendors, but also SaaS platforms, data analytics providers, payment processors, development partners, and other outsourced ICT services.
The Register of Information must clearly document:
- The services provided by each ICT third party
- The business functions supported
- Whether those functions are critical or important
- The contractual structure and associated risk exposure
These records are not merely internal documentation. National competent authorities — such as central banks and financial supervisory authorities — rely on this data. It is subsequently shared with the European Supervisory Authorities (EBA, ESMA, and EIOPA), particularly in the context of identifying critical ICT third-party providers subject to EU-level oversight.
This elevates the RoI from an internal compliance file to a key supervisory dataset.
Why fintechs underestimate the complexity
Fintech companies are inherently technology-driven. Their business models depend on layered digital ecosystems, API integrations, modular infrastructure, and outsourced services. This agility fuels innovation — but it also multiplies dependency risks.
The hidden complexity of the Register of Information typically emerges in three areas:
1. Fragmented data ownership
Procurement holds contracts. IT manages integrations. Compliance monitors regulatory risk. Legal oversees outsourcing clauses. Rarely is supplier data centralized in a structured and harmonized format.
2. Continuous change
Fintechs evolve quickly. Vendors are added, services expanded, contracts amended, cloud architectures redesigned. A static spreadsheet cannot reflect this dynamic reality.
3. Criticality assessment challenges
Determining whether a function is “critical or important” under DORA requires cross-functional analysis. Misclassification can expose the firm to supervisory findings.
What appears to be a documentation exercise quickly becomes a cross-departmental governance challenge.
Why Excel is no longer enough
Many fintechs initially relied on spreadsheets to build their Register of Information. While Excel offered a practical starting point during the implementation phase, it falls short in 2026 for several reasons.
Spreadsheets lack structured validation aligned with regulatory technical standards. They provide limited version control and audit traceability. Manual updates increase the likelihood of inconsistencies, duplicate entries, and outdated classifications.
More importantly, European supervisory authorities have introduced structured reporting expectations that require machine-readable, standardized data formats. Transforming manually maintained spreadsheets into compliant submission-ready datasets often becomes a labor-intensive and error-prone process.
As supervisory focus shifts from “existence of documentation” to “quality, integrity, and governance of data,” manual approaches increasingly expose fintechs to operational and regulatory risk.
The register of information as a strategic governance tool
Forward-looking fintechs are reframing the Register of Information from a compliance burden into a strategic governance instrument.
When properly structured, the RoI provides visibility into:
- Supplier concentration risk
- Overreliance on specific cloud or infrastructure providers
- Systemic dependencies within the digital supply chain
- The operational impact of potential third-party disruptions
This aligns directly with DORA’s broader objectives: strengthening ICT risk management, improving incident response capabilities, and enhancing digital operational resilience testing.
Without a reliable Register of Information, these resilience pillars become difficult to substantiate under regulatory scrutiny.
The role of specialized solutions
Recognizing these challenges, many fintechs are transitioning toward purpose-built solutions designed specifically for DORA compliance and third-party governance.
Specialized platforms allow organizations to centralize supplier data, standardize classification processes, maintain audit trails, and prepare structured outputs aligned with supervisory requirements.
An example of such a solution is https://copla.com/dora-register-of-information/
Copla is increasingly recognized as a trusted partner in this space, supporting financial institutions in structuring and maintaining their Register of Information in a scalable and regulator-ready manner. Rather than replacing internal accountability, solutions like Copla provide the operational backbone required to manage RoI data consistently across teams and jurisdictions.
What “DORA-ready” really means in 2026
Being DORA-ready today goes beyond having documentation stored in a shared folder. It means being able to demonstrate — at any time — that:
- The Register of Information is complete and continuously updated
- Supplier criticality assessments are well documented
- Governance responsibilities are clearly assigned
- Data can be delivered to regulators in a structured and validated format
Fintechs that approach the Register of Information as a living governance framework rather than a one-off compliance project are better positioned to withstand supervisory review and manage digital risk sustainably.
How robust is your register of information?
The hidden complexity of the Register of Information lies in its dual nature: it is both a regulatory obligation and a structural test of operational maturity.
In 2026, Excel-based registers and fragmented processes no longer meet the expectations of European supervision. Fintechs that invest in structured governance, reliable data management, and specialized support solutions gain more than compliance — they build resilience.
For firms asking whether they are truly DORA-ready, the answer often begins with one critical question: how robust is your Register of Information?
