Service user, signing entity, and role confusion
Fix signer, service user, branch, and intra-group mismatches by recording each role in the correct template and using the same contractual arrangement reference number throughout.
What this issue group covers
This page helps when the service user, signing entity, or branch has been attached to the wrong contract role.
In the register, the entity signing the contractual arrangement, the entity making use of the ICT service(s), the branch details, and any intra-group link are recorded in different templates. Those entries can differ and still be correct, but they need to be recorded against the right contractual arrangement and in the right template.
Issues covered on this page
The contract signer and service user are not the same
What this usually means
One entity signed the contractual arrangement, but a different entity is making use of the ICT service(s). That can be correct, but the signing entity and the service user must be recorded in different places.
What to check and how to fix it
Check who signed the contractual arrangement.
If you entered the service user as the signer, correct 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 update Signing entity LEI.
Check which entity is actually making use of the ICT service(s).
If a different entity uses the service, record that entity in ICT service users making use of the ICT services and update Service-user company ID code.
Check whether more than one entity is making use of the same contractual arrangement.
If yes, add a separate row in ICT service users making use of the ICT services for each entity making use of that contractual arrangement.
Check whether the user is a branch.
If yes, make sure the branch is first listed in Branches, then use Service-user company ID code for the head-office entity and Branch ID code for the branch.
These role fields do not match
What this usually means
A legal entity, branch code, or contractual arrangement reference number has been recorded against the wrong template row for the same arrangement.
What to check and how to fix it
Check whether the ICT service(s) are being used by a branch or by the financial entity itself.
If the user is a branch, do not replace the financial entity with the branch.
Check Branches.
If the branch is missing, add it first. If it is already there, confirm Branch ID code and Head-office ID codeare correct before you change the service-user row.
Check ICT service users making use of the ICT services.
If the user is a branch, keep the head-office LEI in Service-user company ID code, set Is reporting company a branch? to branch, and enter the branch code in Service-user branch ID code.
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) separately.
If another entity signed the contractual arrangement, keep that entity in Signing entity LEI.
Check that the same contractual arrangement uses the same Contractual arrangement reference number across the relevant templates.
If the same arrangement has been given different reference numbers in Contract general information, Receiving company signatories, ICT service users, or Intra-group arrangements where relevant, correct the rows so they point to the same arrangement consistently.
I am not sure how to report this contract
What this usually means
The contractual arrangement sits in an intra-group chain. One entity within scope may provide ICT service(s) to another entity within scope, or an ICT intra-group service provider may sit between the entity making use of the ICT service(s) and the direct ICT third-party service provider.
What to check and how to fix it
Check whether the ICT service supply chain contains an ICT intra-group service provider.
If it does not, you do not need a row in Intra-group arrangements for that arrangement.
Check Contract general information for the contractual arrangement between the entity making use of the ICT service(s) and the ICT intra-group service provider.
If it is missing, add it first and use its contractual arrangement reference number.
Check Contract general information for the linked contractual arrangement between that ICT intra-group service provider and its direct ICT third-party service provider.
If it is missing, add that contractual arrangement too.
Check Intra-group arrangements.
Enter the reference number of the contractual arrangement between the entity making use of the ICT service(s) and the ICT intra-group service provider in Contract reference ID, and enter the linked upstream contractual arrangement in Contract reference for ICT services referred in Contract reference ID.
Check whether a financial entity within scope is signing a contractual arrangement for providing ICT service(s) to another entity within the scope of consolidation.
If yes, record that provider-side role in Provider company signatories signing the contractual arrangements for providing ICT service(s) to other entities within the scope of consolidation.
Check ICT service users making use of the ICT services.
If more than one entity within scope is making use of the ICT service(s) under that contractual arrangement, add a separate row for each entity making use of that contractual arrangement.
What to do next
After you correct the role mapping, check the same contractual arrangement reference number across the relevant rows one more time. The signing entity, service user, branch details, and any intra-group link should each sit in the right template for that same arrangement.