"Not applicable" and other generic values in ICT provider fields
The Central Bank of Ireland named a generic provider name as an example of a data quality check. The CSSF guide shows where a coded Not applicable value fits.
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What the sources say
The Central Bank of Ireland (CBI) wrote about the data quality feedback announced by the EBA:
"We have been given examples of some of the checks which will be performed" (Z-11)
The second example on the CBI page:
"A generic value reported for the name of the ICT third-party service provider: not applicable" (Z-9)
"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." (Z-10)
The guide of the Commission de Surveillance du Secteur Financier (CSSF, Luxembourg) on the submission of the register, written after the first year of submission, describes a coded "Not applicable" value for three country fields:
"As the data fields B_02.02.0130, B_02.02.0150 and B_02.02.0160 are considered as key fields, they cannot be empty." (Z-14)
"In case the mandatory key value is not known by the financial entities for one of those three fields, they shall specify the code ‘eba_GA:qx2007’ representing the value ‘Not applicable’." (Z-15)
What this means for your register
The two sources point in different directions, and the difference is the lesson. In the CSSF guide, "Not applicable" is a code from a closed list, named for three specific key fields. In the CBI example, "not applicable" is free text typed into the name of a provider, which is a field that describes a real company. A free-text value can pass a check that only asks whether the cell is filled and still be named as an example of a data quality check.
How to check before filing
- Search the whole register for free-text fillers such as "not applicable", "n/a", "unknown", "tbc", "-" and "0" in name and identifier fields.
- For each hit, decide whether the field takes a coded value from a closed list or a real value. A coded value comes from the list, not from typed text.
- In provider rows, the name fields describe a real company. If you do not know the name yet, the row is not finished.
- Related rule page: v8851_m, rule summary: "If any other data column in a B_05.01 provider row is filled, the legal name (c0050) must be filled too."
Sources
- Z-11, Z-9, Z-10: Central Bank of Ireland, https://www.centralbank.ie/regulation/digital-operational-resilience-act-dora/reporting-registers-of-information, read 2026-10-14.
- Z-14, Z-15: CSSF, CSSF guide concerning the submission of DORA Register of information, https://www.cssf.lu/wp-content/uploads/CSSF-guide-for-submission-of-RoI.pdf, read 2026-10-14.
This page is general information and is not legal advice.