Among all the requirements introduced by DORA, few have caused as much practical difficulty as the Register of Information. On paper, it sounds straightforward: a complete record of every ICT third party supporting a financial entity's critical or important functions. In practice, many organizations have found that pulling this information together from contracts, emails and departmental spreadsheets takes far longer than expected. This article walks through what the register actually requires and how to build one without it consuming half a year of your team's time.

What the register needs to contain

The DORA Register of Information is meant to give both the organization and its regulator a clear, current view of ICT third party dependencies. For each provider, it should capture the subject matter of the service, where relevant data is stored and processed, any subcontractors involved, and a documented exit strategy should the relationship end. Providers must also be assessed for criticality, since stricter contractual and audit requirements apply to those supporting critical or important functions.

Regulators have already indicated that gaps in the register are among the first things they look for during supervisory reviews, which makes this far more than a paperwork exercise.

Why it tends to take so long

The usual bottleneck is not understanding the requirement. It is locating the information. Contracts sit with procurement, technical details sit with IT, and criticality judgments often live only in the heads of a few senior staff. Bringing all of this together manually means chasing multiple departments, reconciling inconsistent records, and repeating much of that work every time a contract changes or a new vendor is onboarded.

A more manageable approach

Rather than treating the register as a single, exhausting project, it helps to break the work into stages. Start with the providers supporting your most critical functions, since these carry the highest regulatory and operational stakes. Build a simple, consistent template covering the fields DORA requires, and apply it uniformly rather than adapting it case by case. Then treat the register as a living document, updated whenever a contract changes, rather than a static file that becomes outdated the moment it is finished.

Doing this well from the outset also avoids a common trap: producing a register once for an audit and then letting it drift out of date within months, only to face the same scramble the next time it is requested.

Where a dedicated platform helps

This is exactly the kind of structured, ongoing record keeping that becomes far easier with the right tool. Cynapze maintains a continuously updated register of providers alongside their security scores, criticality ratings and remediation history, so the information regulators ask for is already organized rather than assembled under pressure. Teams that have tried to do this in spreadsheets often find that the biggest gain is not the register itself, but no longer having to rebuild it from scratch every time.

If your organization is still piecing its register together manually, it may be worth seeing how this process looks with proper tooling behind it. Booking a demo with Cynapze takes a few minutes and shows exactly how the register stays current without extra manual work.

Conclusion

The Register of Information is one of the clearest, most concrete deliverables DORA asks for, and also one of the easiest to underestimate. Organizations that treat it as a one time project tend to find themselves repeating the effort every year. Those that build it as a living record from the start, ideally supported by tooling designed for the purpose, turn a recurring burden into a routine part of how they manage third party relationships.

Reach out to Cynapze to see how your Register of Information can stay accurate with far less manual effort.