Entity, branch, and group structure issues
Troubleshooting guide for fixing entity, branch, parent-LEI, acting-on-behalf, and consolidation mismatches in DORA register records by checking the right records, links, and reporting scope.
What this issue group covers
This page groups the most common structure problems that affect how entities, branches, and group relationships should be recorded in the register. These issues usually come from reporting the wrong role, linking a branch incorrectly, or creating inconsistencies between entity-level and consolidated data.
Issues covered on this page
- This entity does not fit the expected register role
- This branch is not being reported correctly
- My direct parent LEI is causing an issue
- I do not know how to report this entity
- My consolidated and entity-level data do not match
This entity does not fit the expected register role
What this usually means
The same party has been put into the wrong register structure. In practice, that usually means a financial entity that belongs in Reporting company’s subsidiaries field has been treated like a branch, or an ICT intra-group service provider that belongs in Providers has been treated like an entity in scope.
This role mismatch can also affect Contract signatories and ICT service users — the Registry areas that correspond to B_03 and B_04 in the DORA RoI templates.
What to check and how to fix it
Check whether the party is a financial entity that belongs in Reporting company’s subsidiaries.
If it is, record it there and do not use a branch or provider record instead.
Check whether the same party has been entered in Branches.
If it is only a branch, keep it in Branches and link it to the correct financial entity; if it is a separate financial entity, remove the branch treatment and keep the entity record in Reporting company’s subsidiaries.
Check whether the party is actually an ICT intra-group service provider.
If it provides ICT services within the group, record it in Providers and use the relevant Contract signatories or ICT service users records for the signing or service-use relationship instead of treating it as a financial entity in scope.
Check Receiving company signatories signing the contractual arrangements for receiving ICT service(s) or on behalf of the entities making use of the ICT service(s) and ICT service users making use of the ICT services.
If the party only signs for another in-scope financial entity or only uses services, correct those relationship records rather than changing the entity’s role in Reporting company’s subsidiaries.
Check whether another entity is acting on behalf of the financial entity for all activities.
If that is the setup, keep the financial entity in scope and record the acting-on-behalf arrangement without replacing the financial entity in Reporting company’s subsidiaries.
Check the same party across Reporting company’s subsidiaries, Branches, and Providers.
If it appears as an entity in one place, a branch in another, and a provider in another without a clear reason, correct the role in each record so the structure lines up.
This branch is not being reported correctly
What this usually means
The branch record itself is wrong, or it is linked to the wrong financial entity. In the register structure, branches are reported separately in Branches and linked back to the financial entity head office.
What to check and how to fix it
Check whether the record belongs in Branches at all.
If the party is a separate legal entity, remove it from Branches and report it in Reporting company’s subsidiaries instead.
Check Branch ID code.
If the branch does not have its own branch identification code, or the wrong code has been used, correct that field first.
Check head-office entity ID code of the branch.
If that LEI does not match the correct financial entity in Reporting company's ID code, fix the head-office link before reviewing anything else.
Check whether the same branch has also been entered as if it were its own entity in Reporting company’s subsidiaries.
If it has, remove the duplicate entity treatment and keep the branch only in Branches.
Check Branch name and Branch registration country.
If the branch record points to the wrong location or branch name, correct those fields so the branch can be matched to the right head office.
Check whether the record is being used to represent an ICT provider or another relationship record.
If it belongs in Providers or in the relevant Contract signatories/ICT service users records instead, move it out of Branches and classify it there.
Related issues
My direct parent LEI is causing an issue
What this usually means
The value in LEI of the direct parent undertaking of the financial entity does not match the reporting scope used for this register. That usually means the wrong parent has been used for the individual, sub-consolidated, or consolidated view.
What to check and how to fix it
Check which reporting level this register is meant to cover.
If you are preparing an individual register, do not use a group parent just because the entity belongs to a wider group.
Check Direct parent company’s LEI.
If that field points to the wrong parent for the reporting scope you are using, replace it with the correct direct parent undertaking.
Check whether the register should be reported on an individual basis because the parent undertaking is outside the Union and there is no Union parent undertaking.
If that applies, stop forcing a group parent into Direct parent company’s LEI and prepare the register on the individual basis instead.
Check whether the entities listed in Reporting company’s subsidiaries match the parent structure implied by Direct parent company’s LEI.
If the parent field points to one group but the entity list reflects another scope, correct the scope first and then correct the parent field.
Check the same field across the entity-level and group-level records for the same financial entity.
If Direct parent company’s LEI changes without a reporting-scope reason, align it to the parent that belongs to that level of reporting.
Check whether a suitable consolidated parent exists for the reporting scope you are using.
If it does not, use the reporting level that applies to that entity and competent authority instead of forcing one parent chain into the register.
Related issues
I do not know how to report this entity
What this usually means
Another entity carries out all activities for the financial entity, including ICT services, and the register has been built around the acting entity instead of the financial entity. The reporting obligation still sits with the financial entity.
What to check and how to fix it
Check whether the financial entity itself is still recorded in Reporting company’s subsidiaries.
If it is missing, add or restore that entity record first.
Check Company.
If another entity maintains the register on behalf of the financial entity, record that role there without replacing the financial entity in Reporting company’s subsidiaries.
Check whether the direct ICT third-party providers used for that setup are being recorded in the financial entity’s register.
If those providers have only been attached to the acting entity outside the financial entity’s register, move the relevant records into the financial entity’s register.
Check whether the acting entity has been entered in Reporting company’s subsidiaries as though it were the financial entity in scope.
If that has happened, correct the entity record and keep the acting entity only in the role supported by the relevant record.
Check whether the acting entity is actually an ICT intra-group service provider.
If it is, record it in Providers and in the relevant Contract signatories/ICT service usersrelationship records rather than as the financial entity in scope.
Check Company, Reporting company’s subsidiaries, and the related provider and relationship records together.
If one record treats the acting entity as the reporting entity and another treats the financial entity as the reporting entity, correct the setup so those records line up.
Related issues
My consolidated and entity-level data do not match
What this usually means
The same entity, branch, contract, function, or provider has been recorded differently between the entity-level and the group-level register. That usually comes from scope differences or from identifiers changing during consolidation.
What to check and how to fix it
Check whether the entity list in Reporting company’s subsidiaries is complete for the consolidation scope you are using.
If entities are missing or extra entities have been added, correct that list first.
Check whether Direct parent company’s LEI supports the same reporting scope at both levels.
If the parent field points to different group structures without a reporting reason, align it to the correct scope.
Check the same branch records in Branches.
If a branch is linked to one head office at entity level and to another at group level, correct head-office entity ID Code.
Check whether the same contractual arrangement reference numbers, function identifiers, LEIs, and provider identifiers are being used in the entity-level and group-level records.
If those identifiers change between levels, correct them before revalidating.
Check Receiving company signatories, ICT service users, and Providers for the same arrangement.
If one level shows the wrong signing entity, service user, or provider, correct those relationship records so they match the underlying entity data.
Check the mismatch in the source record before revalidating or exporting.
If the problem started in the entity-level record, fix it there first and then rebuild the consolidated view from the corrected data.