The EU’s Digital Operational Resilience Act (DORA) became applicable on 17 January 2025. For many European businesses – especially those providing technology services to financial institutions – this regulation introduces a concrete new requirement for financial entities: they must record a standardised identifier for each ICT third-party service provider in their register of information.
What is DORA?
DORA is an EU regulation designed to strengthen the digital resilience of the financial sector. It applies to banks, insurers, investment firms, payment institutions, and a wide range of other regulated financial entities across all EU member states, including Ireland.
Its core aim is to ensure that financial entities can withstand, respond to, and recover from ICT-related disruptions – whether caused by cyberattacks, system failures, or third-party technology outages.
Who does DORA affect?
DORA applies directly to regulated financial entities. Irish companies providing ICT services to these entities – such as software development, cloud hosting, data analytics, cybersecurity, or other technology services – are not directly regulated by DORA, but are directly affected because DORA’s requirements fall on the EU client, who must record a standardised identifier for every ICT provider in their register.
Under DORA, financial entities must maintain a register of information covering all contractual arrangements for ICT services provided by ICT third-party service providers.
For each provider in this register, the financial entity is required to record a standardised identifier:
- For providers that are legal persons established within the EU: an LEI or EUID
- For providers that are legal persons not established in the EU: an LEI
For a closer look at how this works in practice, the GBRIS blog covers automating DORA’s ICT third-party register with verified EUID data in detail.
This means that if your company provides ICT services to a regulated financial institution in the EU, your client needs a standardised identifier to include you in their DORA register – an LEI or EUID. As an Ireland-registered business, you are established within the EU, which means your client may use either an LEI or an EUID for you. Many companies still opt for an LEI because it is internationally recognised and can be used beyond DORA register context.
What is an LEI?
A Legal Entity Identifier is a unique 20-character code that identifies a legal entity in financial and regulatory systems worldwide. It is issued by GLEIF-accredited LEI Issuers (also known as Local Operating Units, or LOUs), often accessible via registration agents and is widely used across financial regulatory frameworks globally, including EMIR, MiFID II, SFTR and others.
You can check whether your entity already has an LEI using the GLEIF’s public search tool.
The renewal requirement
An LEI is not a one-time registration. It must be renewed annually to remain active. A lapsed LEI remains a valid identifier in the GLEIF system, but it signals that renewal is overdue – and some counterparties and onboarding processes may prefer it to be current.
According to GLEIF data, the global LEI renewal rate is around 62%. This means a significant share of registered LEIs worldwide are not currently renewed on time.
Before assuming your company’s LEI is valid, it is worth verifying its current status in the GLEIF database.
What to do now
Check whether your company has an active LEI. Use the GLEIF public registry to verify the status. If your LEI has lapsed, you can renew it quickly on our website.
Register an LEI if you don’t have one. DORA is already in effect, and financial institutions are actively building and auditing their ICT registers. As an Ireland-registered business, you are established within the EU – your client may use an LEI or EUID to identify you. An LEI is internationally recognised and widely used across financial regulatory frameworks.
Keep your LEI data up to date. Outdated entity information is a common issue that can cause problems during client onboarding and regulatory checks.
You can register a new LEI or renew an existing one through LEI Ireland – an Official LEI Registration Agent operating under EQS Group GmbH, a GLEIF-accredited Local Operating Unit.