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RegisterBench

DORA register of information for Luxembourg and Irish fund managers

This page collects what the CSSF, the CBI and the AFM published about the 2026 DORA register of information collection, read on 18 October 2026.

Last reviewed

What the supervisors published

Luxembourg, CSSF. In a communique marked "Published on 17 March 2026" [S-2], the CSSF wrote: "As of 16 March, only 40% of financial entities required to submit their register of information to the CSSF have done so." [S-2] The same communique states: "The register of information has to be submitted to the CSSF by 31 March 2026" [S-2]. In its communique on the 2026 submission timeframe and the eDesk portal, the CSSF wrote that "a register of information which was accepted last year, may be rejected this year" [S-3].

Ireland, Central Bank of Ireland (CBI). On its page about reporting registers of information, the CBI wrote that "The EBA announced, in the week commencing 16 Feb 2026, that there will be an additional review step to be performed on the content of the data submitted in the Registers of Information" [S-1], and that "in April 2026, the EBA will run Data Quality (DQ) checks on all Registers" [S-1]. The same page states: "Firms can reduce the likelihood of being asked to make a resubmission by checking that the content of the data makes sense before final submission." [S-1]

Netherlands, AFM. The AFM published the answers "from a Q&A session about the information register held in March 2026" [S-5]. To the question whether last year's submission can be sent again, the AFM answered: "Submitting the 2025 version will likely result in error messages." and "You may, however, use the 2025 submission as a basis for the 2026 submission." [S-5] On its register of information page, the AFM states: "You can only submit your register of information to us in xBRL-CSV, not in a standard Excel file." [S-4]

What this means for a fund manager's register

  • The CSSF figure described the state of submissions on 16 March, 15 days before the 31 March 2026 deadline named in the same communique, and the communique was published on 17 March 2026 [S-2].
  • The CSSF figure covers all financial entities required to submit a register of information to the CSSF. The quoted sentence gives no split by sector, so it does not say how fund managers compared with other entities [S-2].
  • For the 2026 collection, the CBI relayed an EBA announcement of a review of data content, set for April 2026, after the initial collection [S-1]. The CSSF wrote that "a register of information which was accepted last year, may be rejected this year" [S-3]. Both statements describe a register being checked again after an earlier step: by the EBA after national collection in the CBI text, and from one year to the next in the CSSF text.
  • The AFM answer treated the 2025 file as a starting point for 2026, not as a file to send again unchanged [S-5].

Where RegisterBench fits

  • The RegisterBench home page states: "RegisterBench shows what changed since the register you filed last year and turns rejection feedback back into the flagged rows to fix." [S-6]
  • On last year's file: "Start from an existing workbook, from a CSV export or from last year's reporting package instead of from an empty sheet." [S-6] and "This cycle is compared with the previous one, so you can see exactly what changed before you file." [S-6]
  • On rejection feedback: "Load the feedback you received, and the error codes in it are mapped onto the rows and columns that produced them, so the remediation window is spent fixing rather than searching." [S-6]
  • On identifiers: "Every legal entity identifier is checked in the editor, on every row, as you build the register - its format and its check digits." [S-6] The rule list at https://registerbench.com/rules/ includes "STRUCT-LEI-CHECKSUM - LEI check digits must verify (ISO 17442)" [S-8].
  • What it does not do: "It does not file anything for you." and "It is not legal advice and it does not interpret the regulation for you." [S-6]
  • Plans are listed at https://registerbench.com/pricing/, which states: "Net prices in EUR, per year." [S-7]

Method and limits

  • This page collects what the CSSF, the CBI and the AFM published about the 2026 DORA register of information collection, read on 18 October 2026.
  • Every source was fetched anonymously on 18 October 2026. Times, HTTP codes and body checksums are in the README of this folder. Quotes are verbatim. Each quote was counted on the page text after removing the head, scripts, styles, comments and markup, with entities decoded and whitespace collapsed. Text of PDF files came from pdftotext. Every quote occurs at least once in its source.
  • Not on this page, because no source read on 18 October 2026 contained it: per-sector results of the CBI collection (management companies, AIFMs, insurers), a total count of registers collected by the CBI, a share of registers marked complete without data quality errors, and a share of registers with failed feedback files. The CBI register page, the CBI DORA hub page, the CBI DORA communications page, the CBI DORA FAQ page and the CBI portal guide (PDF) were searched, and none of them contained a percentage figure.
  • The AFM statements come from the Dutch supervisor. They do not describe CSSF or CBI practice.
  • No source quoted here gives a date for the collection after 2026, and this page names none.
  • This page describes what supervisors published and what the software states about itself. It is not legal advice.

Sources