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On April 2, 2026, the National Bank of Belgium (NBB) issued Circular NBB_2026_05 concerning the declaration of an information registry in the context of the Digital Operational Resilience Act (DORA) regulation. The circular applies to a broad range of financial institutions operating in Belgium, including credit institutions, investment firms, insurance and reinsurance undertakings, market infrastructures, securities account keepers, payment institutions, and electronic money institutions (EME). The circular addresses reporting and regulatory compliance requirements related to DORA implementation, which establishes a framework for managing operational resilience and digital risks across the European financial sector. DORA, which came into effect across the European Union, requires financial entities to maintain robust digital operational resilience capabilities, including measures to manage information and communication technology (ICT) risks. The information registry declaration requirement forms part of these compliance obligations, enabling the NBB to monitor and assess institutional readiness and adherence to the regulation's operational resilience standards. Financial institutions subject to NBB supervision should review the circular to understand their specific declaration obligations and ensure timely compliance with the information registry requirements. The circular is available in PDF format on the NBB website and provides detailed guidance on the implementation procedures and reporting mechanisms required under DORA. **Reference:** National Bank of Belgium, Circular NBB_2026_05: Declaration of the Information Registry in the Context of DORA Regulation (April 2, 2026)

On April 2, 2026, the National Bank of Belgium (NBB) issued Circular NBB_2026_05 on the Declaration of the information register under the Digital Operational Resilience Act (DORA). The circular is addressed to various financial institutions operating in Belgium, including credit institutions, investment firms, payment institutions, e-money institutions and crypto-asset service providers. The circular revises Circular NBB_2025_03, on the same topic in order to extend the scope to branches established in Belgium of credit institutions and stock brokerage firms subject to the law of a third country, implementing Article 28(3)(4) of DORA concerning the mandatory notification of the information register. Under Article 28, financial entities are required to maintain and update, at the entity level and at sub-consolidated levels, a register of information on all contractual agreements for the use of ICT services provided by third-party service providers. Through the circular, the NBB provides clarifications regarding the submission of the information registers: The NBB will receive these reports via its OneGate platform, and it has set up a website providing practical information on how to submit the report. The NBB will limit itself, as a general rule, to requesting the information register relating to the highest level of (sub-)consolidation over which it exercises supervision. The information reports submitted to the NBB must contain only information on financial entities within the meaning of Article 2(2) of the DORA Regulation that are subject to the NBB’s supervision (on an individual, sub-consolidated or consolidated basis). The NBB will transfer these information registers only to the European Supervisory Authorities if the financial entity does not have a higher level of consolidation in another member state of the European Union. This circular replaces Circular NBB_2025_03 on the reporting of the information register under DORA, and it shall apply with immediate effect.

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Belgium's National Bank Issues Circular on Digital Operational Resilience Act Information Registry Declaration

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National Bank of Belgium Issues Circular on DORA Information Register Submission