Referential integrity between the B_xx templates
What the CSSF guide, the EBA FAQ and the Central Bank of Ireland say about keys and foreign keys between the templates of the register of information.
Last reviewed
What the sources say
The guide of the Commission de Surveillance du Secteur Financier (CSSF, Luxembourg) on the submission of the register:
"A data field is a foreign key meaning that the value of that data field shall be defined in a data field in the same or in another template." (Z-16)
"an error message of type “Foreign Key Violation” will be issued leading to the rejection of the submitted register" (Z-17)
"Dependencies may also exist inside a single table." (Z-21)
The RoI reporting FAQ published by the EBA, on empty key values:
"will not pass the referential integrity checks and the whole reporting file will be rejected" (Z-18)
The same FAQ, on adding rows for several countries:
"duplicative key values will trigger referential integrity data quality checks" (Z-20)
The guide of the Central Bank of Ireland (CBI) to submitting registers on its portal:
"The EBA data model also denotes which fields in tables are linked (referential integrity), so please take note of this, as ignoring this caused many errors in the first submission." (Z-19)
What this means for your register
The register is a set of linked tables, not a set of separate sheets. A contract reference, a provider code or a function identifier used in one template points to a row defined in another template, or in the same one. If the target row is missing, the CSSF guide describes the result as a rejection of the submitted register. If the same key appears twice, the EBA FAQ describes a data quality check. The CBI guide says that ignoring these links caused many errors in the first submission.
How to check before filing
- For every reference column, list its values and confirm that each one exists as a key in the template it points to.
- Look for keys that appear twice in the same template, especially after rows were added for several countries.
- Check references inside one table too, for example a subsequent arrangement that points to its overarching arrangement.
- When a row is deleted, search for every reference to its key in the other templates.
- Related rule page: v8805_m, rule summary: "If c0020 in a B_02.01 row is eba_CO:x3 (subsequent or associated arrangement), c0030 (overarching arrangement reference) must be filled."
Sources
- Z-16, Z-17, Z-21: 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.
- Z-18, Z-20: EBA, DORA RoI reporting FAQ (updated version), https://www.eba.europa.eu/sites/default/files/2025-03/31bb6e60-7d10-4405-a8c5-9f04934630ac/20250328%20-%20DORA%20RoI%20reporting%20FAQ%20%28updated%29.pdf, read 2026-10-14.
- Z-19: Central Bank of Ireland, Guide to Submitting DORA Registers of Information on the Central Bank of Ireland Portal, https://www.centralbank.ie/docs/default-source/regulation/dora-templates/guide-to-submitting-dora-registers-on-the-central-bank-of-ireland-portal.pdf?sfvrsn=92386a1a_25, read 2026-10-14.
This page is general information and is not legal advice.