The DORA Register of Information for investment firms

An investment firm fills in the same Register of Information as any other financial entity, and files it with the AFM the same way. Three things differ: who falls under DORA, the code for the type of entity, and the licensed activities in B_06.01. This page covers only those differences. The route from workbook to AFM Portal is in the guide to filing with the AFM.

Does DORA apply to you

Yes. DORA lists investment firms in Article 2(1)(e). Persons exempted under Articles 2 and 3 of MiFID II (Directive 2014/65/EU) are excluded (DORA, Article 2(3)(d) (opens in a new tab)).

• Small and non-interconnected: for small and non-interconnected investment firms, Article 16 replaces Articles 5 to 15 with a simplified ICT risk management framework. The register is in Article 28(3), which Article 16 does not exclude. The register therefore applies to you as well (DORA (opens in a new tab)).
• Supervisor: for investment firms, the competent authority under DORA is the one designated under Article 4 of Directive (EU) 2019/2034 (DORA, Article 46(c) (opens in a new tab)). The AFM lists investment firms among the undertakings DORA targets (AFM (opens in a new tab)).

If you must file with the AFM, a reporting obligation is waiting for you in the AFM Portal (AFM (opens in a new tab)).

Type of entity in B_01.01 and B_01.02

You enter eba_CT:x599, described in the EBA's list as "Investment firms". The field is a closed list of codes (EBA, list of possible values (opens in a new tab)).

Template	Field	What you enter
B_01.01	0040 Type of entity	The type of the reporting entity: eba_CT:x599
B_01.02	0040 Type of entity	Each entity in scope gets its own type; for yourself eba_CT:x599

Other entities in your group get their own type in B_01.02, from the same list.

Licensed activities in B_06.01

In B_06.01 (field 0020) you give the licensed activity of each function. The EBA's Annex 2 list maps these codes to investment firms (EBA (opens in a new tab)):

Code	Label (EBA)	Basis in MiFID II, Annex I
eba_TA:x133	Reception and transmission of orders	Section A, point 1
eba_TA:x134	Execution of orders on behalf of clients	Section A, point 2
eba_TA:x173	Dealing on own account	Section A, point 3
eba_TA:x136	Portfolio management	Section A, point 4
eba_TA:x137	Investment advice	Section A, point 5
eba_TA:x138	Underwriting of financial instruments and/or placing of financial instruments on a firm commitment basis	Section A, point 6
eba_TA:x139	Placing of financial instruments without a firm commitment basis	Section A, point 7
eba_TA:x140	Operation of an MTF	Section A, point 8
eba_TA:x141	Operation of an OTF	Section A, point 9
eba_TA:x175	Safekeeping and administration of financial instruments for the account of clients	Section B, point 1
eba_TA:x143	Granting credits or loans to investors	Section B, point 2
eba_TA:x144	Advice to undertakings on capital structure, industrial strategy and related matters and advice and services relating to mergers and the purchase of undertakings	Section B, point 3
eba_TA:x104	Foreign exchange services	Section B, point 4
eba_TA:x146	Investment research and financial analysis	Section B, point 5
eba_TA:x147	Services related to underwriting	Section B, point 6
eba_TA:x204	Investment services related to the underlying of the derivatives	Section B, point 7

For supporting functions, every type of entity uses eba_TA:x276, "Supporting function".

• One identifier per combination: if a function serves several activities, create a separate function identifier for each combination of LEI, function and activity (AFM Q&A (opens in a new tab)).
• Validity: the EBA published the list for the 2025 reporting, under data model 4.0. The AFM says the data model did not change for 2026 (AFM Q&A (opens in a new tab)).

More than one licence, or crypto services

One LEI gets one type of entity. If your firm fits more than one type, choose one for B_01.02.0040 and ask your supervisor which. The register must still cover the contracts and ICT providers of all your activities (EBA FAQ Q10 (opens in a new tab)).

Crypto services are one case. An investment firm may provide crypto-asset services equivalent to the investment services it is authorised for, after notifying its supervisor at least 40 working days in advance (MiCA, Article 60(3) (opens in a new tab)). The codes for crypto services are on the page for crypto-asset service providers.

Part of a group

If you belong to a group, your register may be part of the group's consolidated register. An entity from another sector that falls within a group's prudential consolidation is included in the group's register and is not reported separately (EBA FAQ Q5 (opens in a new tab)). The level at which you file with the AFM is in the filing guide.

Further reading

• Filing the Register of Information with the AFM
• Choosing a converter
• The template pages for B_01.01, B_01.02 and B_06.01