Which service arrangements belong in the register?
Settle the population before you map it.
Read the questions →Scope tells you what belongs in the register. Mapping decides whether it will validate. The work is almost entirely about allocating keys once and letting every other row point at them.
Commission Implementing Regulation (EU) 2024/2956 defines a relational model, not a set of forms. Rows carry keys; other rows reference those keys. Nothing is repeated. Mapping therefore has two halves: deciding what each key is, and deciding which source system owns it.
The second half is the one that gets skipped. If entity identifiers come from finance, provider identifiers from procurement and function names from the risk register, the references will not resolve, because none of those systems was built to agree with the others.
Start here, because everything else is scoped by it. Each financial entity in the register needs a stable identifier — a legal entity identifier where one exists — together with its position in the group and the level at which the register is being produced.
The contractual arrangement is the unit. One arrangement can be governed by an overarching agreement and can have several entities as parties, so three distinct facts have to be captured separately: the arrangement itself, its relationship to any overarching arrangement, and which entity signed it as against which entities use the services under it.
This is where the register grows, usually by a factor most projects have not planned for. A single contract commonly delivers several ICT services, each with its own service type, start and end dates, notice period, governing law and data location.
| Attribute | Source and pitfall |
|---|---|
| Service type | The supervisory taxonomy value, not the contract’s own wording. Select the closest value and record the reasoning. |
| Dates and notice | From the contract, not the purchase order. Auto-renewal has to be reflected rather than left as a lapsed end date. |
| Governing law | Per arrangement, and frequently different from the provider’s country of incorporation. |
| Data storage and processing locations | Country codes, and often several per service. Rarely present in contract metadata; usually obtained from the provider. |
Each direct provider is entered once, with its identifier and country, and referenced from every service it delivers. Subcontractors supporting a critical or important function are then recorded with their rank in the chain.
Rank is positional, so an omitted intermediate entity shifts everything after it and produces a chain that is internally consistent and wrong. Build the chain from the provider’s own disclosure, and where the arrangement does not require that disclosure, log it as a contractual gap — it cannot be inferred from the firm’s own records.
Functions are catalogued with their criticality determination, then mapped to the services supporting them. Two mapping rules keep this stable:
Assessments — substitutability, exit arrangements and reintegration — attach to the arrangements supporting critical or important functions, and are the last thing mapped because they depend on every determination before them.
Primary instruments only. Each is named in full so the reference remains traceable even if a link moves.
REGREP is an independent software provider. This record explains a reporting framework in plain language and is not legal, tax or regulatory advice. Confirm scope, thresholds and submission dates with your competent authority before you file.
More on this framework, and the module that produces the filing.
Settle the population before you map it.
Read the questions →What a broken key looks like when the validator reports it.
Read the questions →Key allocation and referential integrity enforced on every load.
See the module →Load entities, contracts and providers from the systems that own them. The module allocates and enforces the references between them.