Irish firms to submit Register of Information by March 2026 deadline

Important Updates

Below is an overview of some important updates that firms should be aware of when preparing to submit their Register of Information (“RoI”) to the Central Bank of Ireland (“Central Bank”).

Extended Submission Window

The Central Bank has confirmed an extended submission window for 2026.

• RoI submissions can be made via the Portal from 01 March to 31 March 2026.
• Firms are strongly encouraged to submit early to allow time to remediate any errors.

Updated Submission Guidance

Updated and consolidated Central Bank guidance:

• Consolidation of existing guidance documents into a single document: Guide to Submitting DORA Registers of Information on the Central Bank of Ireland Portal (“RoI Guide”).
• Updates to RoI Guide include:
  • improved explanations of validation outcomes and Portal error messages; and
  • updated guidance to reflect the new EBA XBRL filing rules.

Enhanced Validation Checks

Additional upfront validation checks will be performed by the Central Bank (previously performed when RoIs were submitted to EBA) which include:

• New warning errors (which must be addressed before final Portal sign-off); and
• Non blocking errors (that will not prevent an RoI being submitted but should be corrected where possible).

Enhanced Error Messages

As part of the validation process there will be:

• Clearer error messages;
• Multiple errors displayed at once; and
• Error messages that are more specific in identifying the location of errors.

Industry Briefing

The Central Bank held an industry briefing on Wednesday, 4 February 2026 regarding the 2026 RoI submission.

Key points include:

• No changes to the core EBA data model or to the overall RoI file structure requirements from 2025.
• Common issues identified from 2025 are expected to improve due to enhanced validation (e.g. file structure, missing identifiers, referential integrity errors).
• The Central Bank emphasised the importance of:
  • submitting as early as possible;
  • thorough pre submission checking (in particular, for referential integrity);
  • using the updated Central Bank and EBA guidance (including EBA FAQ); and
  • two Portal users required for submission: (i) uploading; and (ii) sign-off.

EBA Review

In April 2026, the EBA will perform a data quality check on all RoIs (which may necessitate re-submission of the RoI for some firms).

• RoI Guide contains details of data quality checks.
• RoI Guide will be updated once additional information on data quality checks becomes available.

Simmons & Simmons: Supporting Clients Across Ireland and Europe

A broad spectrum of firms across the EU are in scope of DORA and must submit their RoI to the relevant national competent authority during March 2026.

At Simmons & Simmons, our Irish and pan-European teams are at the forefront of advising clients on the practical implementation of DORA.

For further insights or to discuss how Simmons & Simmons can support your firm’s operational resilience journey, please contact our Dublin or European Financial Service Regulatory teams.