Subject Matter
Non-EU ICT service providers without a LEI - conflicting validation rules
Question
When an ICT service provider reported under schedule 05.01 is a legal person outside of the EU, the absence of a EUID and LEI will result in a report validation error rendering the submission of the ROI impossible. Should such service provider be left out of the register or should a dummy EUID be used (preferably issued by ESA to adequately consolidate missing positions)
Subject Matter
Register of Information at sub-consolidated Level
Question
For the purpose of preparing the Register of ICT Supplier Information (RoI) on a sub-consolidated basis, is it necessary to include within the different templates (ref. “B_XX.XX.XXX”) the information pertaining to both the Contractual Agreements that the Entity signs and those that it uses?
Specifically then, the “financial entity maintaining the register of information” is to be considered corresponding to the "entity signing the contractual arrangement" and the "financial entity making use of the ICT service(s)"?
Subject Matter
Definition on ICT services
Question
Article 3 (21) of DORA defines that 'ICT services’ means digital and data services provided through ICT systems to one or more internal or external users on an ongoing basis.

It is not clear whether "digital and data services" should be interpreted as:
Version one: either digital or data services (so two different of sets of activities or
Version two: services which need to be both: digital service and parallel/in the same time data service.