Question 1:
Which dropdown values should I use?
Answer 1:
Within Tabular DORA returns you must use one of the dropdown options in the cells (Which should be blue-shaded in these cases). When Tabular exports to XBRL-CSV the resulting file will include the “converted” QName (aka “short label”) value that is needed for the Regulator’s Portal to consume the file correctly.
Question 2:
Why do some of the drop down lists not match the ITS e.g. for B01.02.0050 “Hierarchy of the financial entity within the group (where applicable)” the Tabular drop-downs are:
1. Entities other than entities of the group; 2. Outsourcing; 3. Parent other than ultimate parent; 4. Subsidiary; 5. Ultimate parent
But COMMISSION IMPLEMENTING REGULATION (EU) 2024/2956 of 29 November 2024 has the following options for this datapoint:
1. The financial entity is the ultimate parent undertaking in the consolidation; 2. The financial entity is the parent undertaking of a sub-consolidated part in the consolidation; 3. The financial entity is a subsidiary in the consolidation and is not a parent undertaking of a sub-consolidated part; 4. The financial entity is not part of a group; 5. The financial entity is a service provider to which the financial entity (or the third- party service provider acting on its behalf) is outsourcing all its operational activities.
Answer 2:
You are correct that they are different and that creates confusion, but our dropdowns are based on the taxonomy. Sometimes there can be discrepancies on the EBA side between the ITS and taxonomy.
Looking at the EBA document “List of possible values for all data fields with drop downs (updated 3 March 2025)” you can see that the Tabular values are following the taxonomy here:
We have to follow the taxonomy when there are discrepancies. You should choose from the tabular (taxonomy) drop-down values, as they are needed to create a valid XBRL file and these are the only ones accepted by the portal.
Question 3:
What are the “xbrl_TVXC” validations in the Tabular validation report?
Answer 3:
These validations check that the cross-table relationships which “should” be checked by Regulator Portal validations. These relationships are set out in the DPM database and visualised in the “Data Model for DORA RoI” (https://eba.europa.eu/sites/default/files/2024-11/0f0f79a0-6f9d-413f-b6f3-917371e404ba/Data%20Model%20for%20DORA%20RoI.pdf).
We say “should” because the EBA describe these checks in the “Overview of technical checks, validation rules and business checks to be applied by the EBA for RoI reporting” document on the Preparations for DORA webpage, but these checks are not part of the xbrl taxonomy itself and must be implemented separately – and until the first live submissions are made it is not possible to verify if and exactly how these will be implemented.
However Tabular should be (if not exactly the same) a close copy of these checks.
Question 4:
What are the “TC_VR_GLEIF” and “TC_VR_GLEIF_CNTRY” validations in the Tabular validation report?
Answer 4:
These validations check that each LEI code included in the DORA submission is present in the GLEIF database (and further a check that the country given in the DORA submission for the LEI matches the country in GLEIF database), which “should” be checked by Regulator Portal validations.
We say “should” because the EBA describe these checks in the “Overview of technical checks, validation rules and business checks to be applied by the EBA for RoI reporting” document on the Preparations for DORA webpage, but these checks are not part of the xbrl taxonomy itself and must be implemented separately – and until the first live submissions are made it is not possible to verify if and exactly how these will be implemented.
However Tabular should be (if not exactly the same) a close copy of these checks.
For example, it is not specified in the available EBA documentation if the GLEIF database if filtered (e.g. to exclude any entries by their status) or which of the available country fields (legal jurisdiction, head office address etc.).
Question 5:
B.99.01 – does this need to be completed?
Answer 5:
We haven’t seen any specific guidance on this point, but we can confirm that there are no XBRL validations that relate to B.99.01
Question 6:
What should we select from the dropdown list for ‘Type of Code to identify the ICT third-party service provider if we don’t have an LEI or EU-ID?
Answer 6:
You can select:
Company Registration Number (CRN)
National Code
Passport Number
VAT
We don’t have a recommendation of which other option to use.
Question 7:
If we only have 1 entry in B.01.02, should B.03.03 always be blank?
Answer 7:
The guidance for B.03.03 states that you should ‘Identify all financial entities referred to in template B_01.02 that have signed contractual arrangements as referred to in template B_02.01 for providing ICT services to other entities in the consolidation referred to in template B_01.02.’. Logically if there is only 1 entry in B.01.02, then it would not be valid to enter a line in B.03.03. However there are no XBRL validations in the taxonomy related to this potentially invalid scenario.
Question 8:
In B.02.01 should we enter any type of contract modification (such as updates, addendums or renewals)?
Answer 8:
This may depend on how you define the three contract arrangement types in B.99.01 C0010, C0020 & C0030.
FAQ #106 gives some general guidance on contract granularity.
Question 9:
Are there definitions available anywhere for the options in each dropdown?
Answer 9:
Six of these are available to be defined yourself in B.99.01, some are ISO codes like currency / country that do not need definitions, some are defined in the ITS.
Question 10:
Is B.02.01 C0050 mandatory for intra-group contracts?
Answer 10:
The guidance states that ‘intragroup transfers’ should be noted in this field. Where relevant this field should be used for this purpose. The ITS states this field is mandatory, but XBRL business validations on this field are only a warning if empty.
Question 11:
Is there an interdependency between c0050 and c0060 in B.05.01 ? Are there any validations with respect to C0060? Should these fields match?
Answer 11:
The only XBRL business validation targeting C0060 is a basic non-empty check.
Question 12:
I can not add all my data to a template without creating duplicate keys. What should I do?
Answer 12:
For your submission to be valid, you must respect the table keys. You should consider whether your data granularity is appropriate in this case.
Question 13:
Not all my providers have 2 identifiers. Can I leave the second blank?
Answer 13:
Please see our guidance against B.05.01 C0030 here:
Our assumption is that the same code should be duplicated across C0030 and C0040.
Question 14:
I get a Tabular blocking error against B.01.02 C0060. I don’t understand this error, my data looks correct.
Answer 14:
Please see the data relationship diagram below:
Our notes on the topic are in B.01.02 C0010 and C0060 here:
Question 15:
I get a Tabular blocking error against B.05.01 C0110. I don’t understand this error, my data looks correct
Answer 15:
Please see the data relationship diagram below:
Our notes on the topic are in B.05.01 C0010 and C0110 here:
Question 16:
I am filing with the CBI and I get an error XBRL-FIL-0001 Invalid File Content.
Answer 16:
When you re-name your ZIP file before submission (as per section 5.2 of the linked guide), please note that you also must rename the folder directly within the zip file to be the exact same name as the name of your zip file.
1) Extract your zip file (right click -> extract all)
2) Rename the folder at the top level of the zip to be your required name
3) Zip the file (using any zip program)
CBI – Guide to DORA ROL Submission
Question 17:
I get a error like the one in the picture below, about incorrect format of our entity code in the XBRL-csv export when loading to our regulator portal.
Answer 17:
You will need to update the string ‘lei’ to ‘rs’ in the H.PARAMETERS sheet in your workbook, then export to XBRL-csv again and try uploading to the portal another time. This is the sheet you must change, the field to update is ‘EntityID’:
Please follow these steps:
1. Go to the H.PARAMETERS sheet in the workbook
2. Put your cursor in cell _C0020_R0010 (entityID)
2. In the Tabular ribbon select Subtotals-> Selected cell -> Remove formulas. This will remove the formula and will make the field editable.
3. Then change the value to rs: from lei: keeping the rest of the string the same.
4. Export to XBRL-csv again.
Question 18:
When Tabular exports my data into XBRL-csv format, the data points are not sorted in numeric order. Does this matter?
Answer 18:
The file is valid regardless of the order of the datapoints.
Question 19:
When Tabular exports my data into XBRL-csv format, the monetary data points contain trailing decimal places – with zero(s). Does this matter?
Answer 19:
The resulting XBRL-csv file is valid regardless of trailing decimal places with zeros.
Question 20:
Can we use non Latin characters in fields where the ITS guidance does not state that only Latin characters must be used.
Answer 20:
Yes, for example you can use the additional Swedish 3 characters (over the standard 26 character Latin alphabet) in data points like the contract reference ID.
Question 21:
In template B.06.01 , the columns identifiers (C0010 etc) do not match the ITS documentation after C0040. Which is correct?
Answer 21:
Tabular reflects the XBRL taxonomy and is therefore correct. The ITS has a missing C0050 identifier and all subsequent columns are ‘off by one place’. For the correct list of columns see our documentation here:
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