DORA TPRM Compliance: Meeting the EU’s Register of Information Requirements

The Digital Operational Resilience Act (DORA) has been directly applicable to EU financial entities and their ICT service providers since January 2025. Compliance is no longer about collecting periodic vendor surveys. Financial entities now have to maintain a Register of Information (RoI) covering every ICT third-party arrangement, assess concentration risk across their vendor base, and subject their most critical providers to direct oversight from EU supervisory authorities. 

A manual, survey-based process cannot track the layered, interdependent vendor base that DORA demands. Without unified third-party risk management (TPRM), organizations risk incomplete records, unmapped fourth-party subcontractors, and severe regulatory enforcement.

The basics: Registers of Information

DORA shifts third-party risk management from static, annual assessments to automated, continuous posture monitoring. Under Chapter V, Article 28, DORA specifically requires financial entities to maintain and submit a highly prescriptive Register of Information (RoI) covering all ICT third-party service providers.

According to DORA, these RoIs serve three core operational purposes: 

• Give financial entities an internal mechanism to actively monitor ICT vendor risk.
• Provide EU competent authorities with clear records to supervise institutional risk posture.
• Give European Supervisory Authorities (ESAs) the data needed to designate and oversee Critical ICT Third-Party Service Providers (CTPPs).

To satisfy DORA’s third-party mandates, GRC teams can meet these requirements by:

1. Centralising vendor security documentation (SOC 2® reports, penetration tests, and custom questionnaires) into a single auditable repository.
2. Using AI-powered third-party risk management (TPRM) to automatically ingest, extract, and analyse vendor evidence in minutes rather than weeks.
3. Continuously monitoring external security posture to detect systemic supply chain concentration risks and vulnerabilities before regulators do.

Spreadsheet-based vendor tracking falls out of date the moment contracts change. DORA requires a dynamic, centralized vendor register directly mapped to an organization’s critical and important business functions.

Register of Information content and reporting requirements

Under DORA Article 28, the RoI requires deep structural data covering the financial entity, direct ICT service providers, subcontracting chains, contract scopes, and the specific business functions supported.

Per DORA Article 28 (3), financial entities must:

• Report annually to the competent authorities on the number of new arrangements on the use of ICT services, the categories of ICT third-party service providers, the type of contractual arrangements, and the ICT services and functions which are being provided.
• Provide records on demand to the competent authority, including the RoI and any additional information deemed necessary to enable the effective supervision of the entity.
• Flag critical changes proactively by informing the authorities in a timely manner regarding planned contracts supporting critical or important functions, or when an existing function is elevated to critical status.

Building your register without starting from scratch

Many organizations lack a real-time view of ICT third-party relationships because vendor data remains split across procurement, legal, and compliance silos.

In our webinar with partner Passeca Germany, CEO Sergiy Lapin advised compliance teams to avoid starting with a blank spreadsheet. Instead, begin with your central contract repository:

1. Seed the inventory: Extract active contracts involving data processing, system access, or cloud infrastructure.
2. Assign criticality: Identify which providers would disrupt customer-facing operations or critical business functions if they experienced 4 hours of downtime.
3. Map the supply chain: Trace critical downstream dependencies and subcontractors before regulators ask for them.

Teams adopting this contract-first approach reach 80% coverage in 2 weeks versus 2 quarters compared to those starting with empty templates.

How Hyperproof simplifies DORA third-party compliance

Moving from DORA preparation to ongoing operational resilience requires the right tools and processes. Hyperproof accelerates this transition with ready-to-use DORA templates, centralized risk management, and automated evidence collection that integrates with existing technology stacks. 

Hyperproof’s Vendor Register gives you a single source of truth for every ICT supplier that falls under DORA’s third-party oversight obligations. By capturing contract identifiers, service classifications, data-location clauses, and exit-strategy provisions in one searchable inventory, you can instantly demonstrate to supervisors that all critical and important providers are documented as required by the regulation. 

Our built-in health widget flags at-risk and critical vendors, while the freshness setting ensures contract evidence is refreshed on a defined cadence, preventing stale or missing documentation. 

Integrated issue tracking surfaces open compliance gaps, like pending security-assessment reports, and the renewals view highlights upcoming contract expirations, prompting proactive renegotiation or termination before a deadline. 

Vendors can be linked to related controls, risks, and proof, so the register automatically aggregates the supporting evidence needed for DORA’s contractual and monitoring checkpoints, turning a traditionally fragmented process into a consistent, auditable workflow.

By using Hyperproof TPRM to automate third-party risk assessments and document reviews, lean GRC teams can eliminate spreadsheet chaos and build continuous operational resilience.

Request a demo to see how Hyperproof TPRM automates vendor risk evaluations, facilitates DORA reporting, and keeps your operational resilience audit-ready.