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WFN QUICK BRIEF · UNDER 1 MIN
The short version
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What the primary record establishes
DORA Article 28(3) requires covered financial entities to keep a register of contractual arrangements for third-party ICT services. It distinguishes arrangements supporting critical or important functions. The implementing regulation sets standard templates. DORA Article 28 ↗EU Implementing Regulation 2024/2956 ↗
What the distinction changes
One provider may host both a public fee page and the infrastructure used for client orders. A list of suppliers alone cannot identify which activity an outage will interrupt. Connect the service to the using entity and supported function.
What to check before drawing a conclusion
Update the register when the dependency changes, such as after a data-center move or a change of backup connectivity provider. In a group, the company signing the contract and the entity using the service can differ, even when payments are centralized.
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WFN STORY COMPASS
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Original WFN vector illustrationWFN · 6 November 2026
Editorial noteSource-based explanation with original WFN analysis. Historical records retain their dates; numerical examples are illustrative. The original vector illustration is conceptual and is not documentary evidence.
The linked source supports the documented record; WFN interpretation and illustrative examples are separate.
01 · VERIFIED RECORD
What the primary record establishes
DORA Article 28(3) requires covered financial entities to keep a register of contractual arrangements for third-party ICT services. It distinguishes arrangements supporting critical or important functions. The implementing regulation sets standard templates. DORA Article 28 ↗EU Implementing Regulation 2024/2956 ↗
02 · WFN EDITORIAL ANALYSIS
What the distinction changes
One provider may host both a public fee page and the infrastructure used for client orders. A list of suppliers alone cannot identify which activity an outage will interrupt. Connect the service to the using entity and supported function.
03 · REVIEW POINTS
What to check before drawing a conclusion
Update the register when the dependency changes, such as after a data-center move or a change of backup connectivity provider. In a group, the company signing the contract and the entity using the service can differ, even when payments are centralized.
