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AI Risk & Compliance

From Excel to XBRL-CSV: how to comply with DORA requirements

Date:December 22, 2025

Since 17 January 2025, the Digital Operational Resilience Act (DORA) has been in force for financial institutions. One of DORA’s many obligations is the maintenance of an Information Register containing an overview of contracted ICT service providers and additional relevant information. This Information Register must be completed in accordance with a prescribed data model. For last year’s supervisory request, the regulators (AFM and DNB) made an Excel template available for this purpose.

At the beginning of December, the AFM and DNB sent an information request requiring the Information Register for 2025 to be submitted by 22 March at the latest (AFM deadline). Unfortunately, the AFM no longer provides an Excel template, and the Register must now be submitted in XBRL-CSV format. This presents a challenge, as specific technical expertise is required to develop a tool that converts the Information Register from Excel to XBRL-CSV. We have done this work for you.

The conversion service

Our Projective Group data specialists have joined forces with our IT Compliance consultants to develop a service that converts your existing Excel file into the required format. While many organisations struggled last year with error reports issued by the supervisors, this is avoided because we have automated the validation rules within the conversion tool itself. Should any errors nevertheless arise, we resolve them promptly by liaising with you to clarify the correct values.

In short, our service provides conversion of the Information Register at a fixed price and without recurring software licence fees. You supply your Excel file, Projective Group performs a quality check and then converts the file in line with the official XBRL-CSV specifications.

The costs are €999 (excluding VAT) for micro-enterprises and Class 3 investment firms, and €1,499 (excluding VAT) for larger organisations, covering successful submission to the supervisor. A prerequisite is that you have already successfully submitted the Information Register to the AFM in 2025. If this is your first submission, we work on the basis of an hourly rate for setup, guidance and conversion.

This means you do not need dedicated DORA software with more functionality than necessary, nor are you tied to recurring licence fees.

Interested or would you like more information? Please email dora@projectivegroup.com