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Regulatory Brief · DORA

DORA Register of Information: Excel template vs SaaS — making the right technical choice

17 May 2026By NexCyber Editorial DORA

In the evolving landscape of financial regulations, compliance with the Digital Operational Resilience Act (DORA) is paramount for financial entities across the EU. One of Europe's largest insurers recently spent 14 months migrating 1,200 contracts from an Excel-based system to a Software as a Service (SaaS) solution for managing their register of ICT third-party arrangements. This transition underscores the complexities and strategic decisions involved in choosing the right technical solution f

In the evolving landscape of financial regulations, compliance with the Digital Operational Resilience Act (DORA) is paramount for financial entities across the EU. One of Europe's largest insurers recently spent 14 months migrating 1,200 contracts from an Excel-based system to a Software as a Service (SaaS) solution for managing their register of ICT third-party arrangements. This transition underscores the complexities and strategic decisions involved in choosing the right technical solution for DORA compliance.

Understanding the EBA ITS Format Requirements

The European Banking Authority (EBA) has outlined specific requirements for the format of the register of information mandated by DORA Article 28. This register must be machine-readable, with JSON or XML being the preferred formats. The purpose of this requirement is to ensure that the data can be easily processed and analyzed by competent authorities.

Key Fields and Structure

The register must include comprehensive information about each ICT third-party arrangement. This includes:

  • Identification of the third-party provider: Name, address, and contact details.
  • Description of services: Detailed information about the services provided.
  • Contractual terms: Duration, renewal options, and termination conditions.
  • Risk assessments: Any identified risks and mitigation strategies.
  • Performance metrics: Service level agreements and performance indicators.

These fields are designed to provide a holistic view of the entity's reliance on third-party ICT services, facilitating better risk management and oversight.

The Pros and Cons of Using an Excel Template

For financial entities managing fewer than 50 ICT third-party contracts, an Excel template might suffice. However, there are inherent limitations and potential pitfalls associated with this approach.

Advantages of Excel

  • Simplicity: Excel is widely used and familiar to most organizations, making it easy to implement without additional training.
  • Cost-effective: For small-scale operations, Excel does not require additional software investment.
  • Flexibility: Users can customize the spreadsheet to fit their specific needs.

Limitations and Challenges

  • Scalability: Excel becomes cumbersome and error-prone as the number of contracts increases, particularly beyond 50.
  • Audit Trail Issues: Tracking changes and maintaining a reliable audit trail is challenging, which can lead to compliance risks.
  • Data Integrity: Manual data entry increases the risk of errors, which can compromise the accuracy of the register.

Features and Benefits of a SaaS Register Solution

For entities managing over 200 contracts, a SaaS solution becomes not only beneficial but necessary to meet DORA's requirements effectively. SaaS platforms offer a range of features that address the limitations of Excel.

API Ingestion and Integration

SaaS solutions typically offer robust API capabilities, allowing for seamless integration with existing systems. This facilitates automated data ingestion, reducing manual entry errors and ensuring that the register is always up-to-date.

Comprehensive Change History

One of the critical advantages of a SaaS platform is its ability to maintain a detailed change history. This feature provides a clear audit trail, essential for compliance audits and internal reviews. It ensures that all modifications to the register are logged and traceable.

Streamlined NCA Submission

SaaS solutions are designed to simplify the process of submitting the register to the National Competent Authority (NCA). With built-in functionalities to generate machine-readable reports in the required format, these platforms reduce the administrative burden and minimize the risk of non-compliance.

Next Step with NexCyber

Choosing between an Excel template and a SaaS solution for your DORA register of information is a critical decision that impacts your compliance strategy. NexCyber offers a comprehensive comparison grid to help you evaluate the best option for your organization based on your specific needs and contract volume. Visit [NexCyber's DORA Register Comparison Grid](https://www.nexcyber.eu/assess?utm_source=editorial&utm_campaign=dora-register-of-information-excel-vs-saas) to explore your options and ensure your compliance with DORA's stringent requirements.