The activities of credit bureaus (credit reporting agencies) are not directly referenced within the scope of DORA. These services may not traditionally seen as "ICT Services", but they could be interpreted as "data services provided through ICT systems". Are these intended to be within scope for ICT services?

Can you elaborate the requirement above? What an effective check should contain and how should be implemented practically?

We are investment company that doesn´t meet DORA requirements to qualify as microenterprise neither as small enterprise since we have more than 10 employees (total of 14) but our annual turnover and/or annual balance sheet total that does not exceed EUR 2 million. What are our obligations under DORA regulation?

Article 13 1. (b) states that Financial instruments with economic effect similar to that of the financial instruments referred to in that point, whether or not they confer a right to a physical settlement are subject to the notification requirement of Article 9 in the TD. The definition of "Financial Instrument" is further elaborated in Article 13, 1b, and its subsequent sub-points, and includeds the wording "any other contracts or agreements with similar economic effects which may be settled physically or in cash.". ESMA has also produced an Indicative List of

Given this context, my question is: Do synthetic shares, which are created through various derivatives and structured financial processes to mimic the performance of actual shares without conferring ownership, fall under the scope of "financial instruments" as defined in Article 13(1)(b) of the Transparency Directive? Specifically, do synthetic shares qualify as "contracts or agreements with similar economic effects" that are subject to notification requirements pursuant to this paragraph?

How can DORA Article 28 be applied on software companies when the financial entity purchases off-the-shelf software licenses? If the off-the-shelf software supports critical or important function, should the DORA Article 28 (8) be applied?