The countdown to the end of Q1 2026 has officially started and for financial institutions across the globe the pressure is no longer theoretical. National Competent Authorities have issued their final warnings regarding the submission of the Register of Information. This is the moment where the industry moves from planning to execution and the stakes could not be higher.

If your organisation is still treating this as a simple data collection exercise you are already behind. The latest move from the European Banking Authority has fundamentally changed the rules of the game by closing the DORA gap once and for all.

The EBA Expansion: Everything is Now Critical

On February 23 the European Banking Authority finalised a shift that many in the industry were hoping to avoid. They have confirmed that the same level of digital rigour applied under the Digital Operational Resilience Act will now extend to non ICT third party risks.

This means that services previously considered outside the scope of DORA such as facilities management legal services and payroll are now subject to the same strict governance. The regulator is sending a clear message: operational resilience is not just an IT problem. It is an enterprise wide mandate. If a third party partner is critical to your business continuity they are now under the regulatory microscope regardless of whether they provide software or physical security.

The Scramble for the Register of Information

The Register of Information is the heart of the Q1 reporting mandate. It is a live map of your entire dependency ecosystem. Most firms are currently struggling with the administrative weight of this requirement because they are relying on manual processes.

A static spreadsheet cannot handle the complexity of modern Nth party relationships. Regulators are looking for more than a list of names. They want to see evidence of concentration risk management and tested exit strategies. They want to see that you have full oversight of the technology layers beneath your primary partners. The Q1 scramble is proving that firms without an automated source of truth are facing massive operational bottlenecks.

Resilience as a Competitive Weapon

The most successful leaders in 2026 are not looking at these deadlines as a burden. They are using them as a competitive weapon. By building a robust and automated governance framework you are doing more than avoiding fines. You are proving to your clients and shareholders that your enterprise is built to withstand systemic failure.

When you can produce a perfect Register of Information at the touch of a button you signal a level of operational maturity that legacy competitors simply cannot match. You move from a state of constant panic to a state of continuous audit readiness.

The Bottom Line for the Board

The Q1 2026 deadline is the ultimate stress test for your third party risk strategy. The expansion of EBA guidelines into non ICT areas means the safety net of “out of scope” vendors has vanished.

Now is the time to centralise your data and automate the heavy lifting of compliance. The firms that survive the scramble will be those that treat resilience as a core business value rather than a checkbox. The era of the DORA gap is over and the era of the resilient enterprise has begun.

Ready to Automate Your Register of Information?

The Q1 deadline is approaching fast. Ensure your organisation is ready with an enterprise grade solution that turns regulatory pressure into a strategic advantage.