Filing the DORA Register of Information with the AFM

You file the DORA Register of Information with the AFM as an xBRL-CSV package in a ZIP file, through the reporting obligation in the AFM Portal. The AFM forwards the package to the EBA and posts the EBA's feedback back in the portal. This guide follows that route from start to finish.

Who files with the AFM

You file with the AFM if you are a financial entity under DORA and the AFM is your competent authority. If you have to file, a reporting obligation is waiting for you in the AFM Portal (AFM (opens in a new tab)).

The level you file at depends on your situation (AFM (opens in a new tab)):

• Individual, if you are not part of a group of financial entities.
• Individual, if you are part of a group whose parent undertaking is outside the EU.
• Highest level of consolidation in the EU, if you are part of a group and the AFM is the competent authority under the Union acts referred to in Article 46 of DORA.

If the parent at consolidated level is not supervised by another competent authority in the EU, you file at the level of the individual entity. DNB collects registers from the institutions it supervises (DNB (opens in a new tab)); this guide covers the AFM only.

What differs by type of firm is in the guides for investment firms, fund managers and crypto-asset service providers.

Format: xBRL-CSV only

The AFM accepts the register only as xBRL-CSV in a ZIP file. An Excel file is not accepted, and iXBRL does not work either (AFM (opens in a new tab)).

Format	Accepted by the AFM
xBRL-CSV in a ZIP file	Yes
Excel workbook	No. The AFM converted Excel once in 2025; that was a one-time service (AFM Q&A (opens in a new tab)).
iXBRL	No

If you keep the register in Excel, you need a converter. The AFM advises one that produces xBRL-CSV, supports the EBA taxonomy and runs thorough data-quality checks straight away. Check, too, what the provider does with your data (AFM (opens in a new tab)). The converter checklist works through those points.

File name

The file name follows a fixed pattern. If it doesn't match, the AFM Portal won't accept the file (AFM (opens in a new tab)). The AFM's example:

DUMMYLEI123456789012.IND_NL_DORA010100_DORA_2025-12-31_YYYYMMDDHHMMSSsss

Part	Meaning
DUMMYLEI123456789012	The LEI of the reporting entity (a dummy value here).
.IND or .CON	.IND for an individual report, .CON for a consolidated report.
NL	Always the same; the country code does not change.
DORA010100	Always the same: the fixed code for the report type.
DORA	Always the same: the reporting framework.
2025-12-31	The fixed reference date for the 2026 request.
YYYYMMDDHHMMSSsss	Timestamp of creation: year, month, day, hour, minute, second and millisecond.

Worked example. An individual report for the 2026 request, created on 15 March 2026 at 09:30:00.123:

DUMMYLEI123456789012.IND_NL_DORA010100_DORA_2025-12-31_20260315093000123.zip

Both the ZIP file and the folder inside it carry this name, without .zip for the folder. The EBA uses the same pattern in its own example in question 24 of the DORA RoI reporting FAQ (opens in a new tab).

ZIP and folder layout

The ZIP file holds one folder with the same name as the ZIP. Inside are META-INF/reportPackage.json and a reports/ folder with report.json, parameters.csv, FilingIndicators.csv and one CSV file per template (EBA Filing Rules (opens in a new tab), EBA CSV guide (opens in a new tab)).

DUMMYLEI123456789012.IND_NL_DORA010100_DORA_2025-12-31_20260315093000123.zip
└── DUMMYLEI123456789012.IND_NL_DORA010100_DORA_2025-12-31_20260315093000123/
    ├── META-INF/
    │   └── reportPackage.json
    └── reports/
        ├── report.json
        ├── parameters.csv
        ├── FilingIndicators.csv
        ├── b_01.01.csv
        ├── b_01.02.csv
        ├── b_01.03.csv
        ├── b_02.01.csv
        ├── b_02.02.csv
        ├── b_02.03.csv
        ├── b_03.01.csv
        ├── b_03.02.csv
        ├── b_03.03.csv
        ├── b_04.01.csv
        ├── b_05.01.csv
        ├── b_05.02.csv
        ├── b_06.01.csv
        ├── b_07.01.csv
        └── b_99.01.csv

What each file must hold:

• report.json points to the DORA module entry point of the EBA taxonomy.
• parameters.csv starts with the header name,value and holds, among others, entityID, refPeriod and baseCurrency (EBA Filing Rules (opens in a new tab)). The entityID value takes the form rs:DUMMYLEI123456789012.IND and must match the LEI in the file name (AFM Q&A (opens in a new tab)).
• FilingIndicators.csv lists all 15 templates, each with the value true, even when a template is empty (AFM Q&A (opens in a new tab), EBA common issues (opens in a new tab)).
• The table files have lowercase names such as b_01.01.csv; uppercase variants were rejected in the EBA's testing (EBA common issues (opens in a new tab)).
• Every file is UTF-8 encoded (EBA Filing Rules (opens in a new tab)).

The EBA publishes sample packages that show what a package looks like (EBA (opens in a new tab)). The file names in your package must match those in the sample; otherwise the EBA treats them as extra files (AFM Q&A (opens in a new tab)).

Uploading in the AFM Portal

You upload the ZIP file to the reporting obligation for the register in the AFM Portal (AFM (opens in a new tab)). You need an account linked to your company.

1. Register a personal account at portaal.afm.nl (opens in a new tab) with your own business email address, not a general company address. Signing in uses multi-factor authentication through an authenticator app (AFM manual (opens in a new tab)).
2. A director links the account to the company, with an extract from the Chamber of Commerce (KvK). If you are not a director, a statutory representative or authorisation manager grants you access (AFM manual (opens in a new tab)).
3. Open the Reporting section and, in it, the reporting obligation for the register.
4. Upload the ZIP file as it was built. Don't unzip and re-zip it: compressing can add hidden folders, and those lead to rejection (AFM Q&A (opens in a new tab)).

On upload, the AFM checks only that the LEI of the reporting entity matches its own records and that the file name follows the convention. The EBA does every other check (AFM Q&A (opens in a new tab)). If the AFM says the LEI is wrong, contact [email protected].

Feedback

The EBA's feedback appears as a .txt file in the reporting obligation in the AFM Portal. Normally within one business day, in exceptional cases within two (AFM (opens in a new tab), AFM Q&A (opens in a new tab)). If it takes longer, email [email protected].

Once the feedback is uploaded, the AFM reopens the reporting obligation so you can file again. The AFM doesn't publish the layout of the .txt file. The EBA does describe its own feedback format; see the EBA feedback files.

Resubmission

You may file as often as you like. Each new submission needs a file name different from the previous ones; change the timestamp at the end (AFM Q&A (opens in a new tab)).

• Give the folder inside the ZIP the same new name, or you get code 103.
• Refiling last year's register unchanged will most likely produce errors. You may use it as a starting point (AFM Q&A (opens in a new tab)).

Deadlines

For the 2026 request: reference date 31 December 2025, first submission by 31 March 2026, corrections welcome until 30 April 2026 (AFM (opens in a new tab)).

2026 request	Date	Source
Reporting obligation available in the AFM Portal	January 2026	AFM (Dutch page) (opens in a new tab)
Reference date	31 December 2025	AFM (opens in a new tab)
First submission completed	by 31 March 2026	AFM (opens in a new tab)
Corrections (resubmissions) welcome	until 30 April 2026	AFM Q&A (opens in a new tab)

On 25 September 2026 the AFM's page gave no dates for the 2027 request yet. We update this table once the AFM publishes them.

Common errors

The AFM names six error codes it sees often. According to the AFM, code 807 is the most common reason for rejection (AFM Q&A (opens in a new tab)).

Code	What goes wrong
103	The ZIP file name doesn't match the name of the folder inside it.
701	report.json, parameters.csv or FilingIndicators.csv is missing.
702 and 808	FilingIndicators.csv has too many or too few template IDs, or a value other than true.
714	entityID in parameters.csv is missing or doesn't match the LEI in the file name.
720	The ZIP contains files the EBA doesn't expect, such as hidden folders.
807	A reference to a key that doesn't exist in the target table.

805 (empty key column) and 809 (CSV formatting) have their own pages too. Every other code is in the error-code reference.

When feedback seems to contradict the ITS

If you can't explain feedback from the ITS, check the EBA's FAQ first, then the data model. In validation the FAQ takes precedence, then the DORA Data Point Model (DPM), and the ITS last (AFM Q&A (opens in a new tab)).

1. The EBA's DORA RoI reporting FAQ (opens in a new tab)
2. The DORA Data Point Model, published on the EBA's DORA page (opens in a new tab)
3. The ITS, Implementing Regulation (EU) 2024/2956 (opens in a new tab)

Sources

This guide rests on the AFM's Register of Information (opens in a new tab) page and its March 2026 Q&A (opens in a new tab). For the package itself: the filing rules, CSV guide, FAQ and sample packages on the EBA's DORA page (opens in a new tab). The full list is below.