Critical or important functions
It's the most structuring notion in the register — and the most scrutinised. It decides the level of requirements on each provider. Here's the definition, how to identify one, and where to declare it.
In short — A critical or important function under DORA is one whose failure would materially impair the financial soundness, the continuity or quality of the entity's services, or jeopardise compliance with its regulatory obligations. You declare it in B_06.01 and assess the service supporting it in B_07.01.
The definition
Under DORA, a critical or important function is a function whose failure would:
- materially impair the financial soundness of the entity, or the continuity or quality of its services; or
- whose disruption would jeopardise compliance with its regulatory obligations or the conditions of its authorisation.
Criticality isn't guessed: it's justified, function by function.
Why it matters in the register
Classifying a function as critical or important triggers a higher level of requirements: it mandates an assessment of the ICT service supporting it and concentrates the supervisor's attention. Getting the boundary wrong means either under-declaring (a compliance risk) or over-declaring (needless burden).
How to identify them
Review your business functions and ask, for each:
- would its disruption directly impact clients or markets?
- is there a quick fallback, or is the dependency strong?
- would a failure trigger a regulatory breach (reporting, payments, custody of assets…)?
- is the function supported by an external ICT provider (and its subcontracting chain)?
The answers build your critical perimeter — document it, because the supervisor may ask for the justification.
Where to declare them in the register
B_06.01— you declare the list of your functions with an identifier and their classification (including criticality);B_02.02— each ICT service is linked to the function it supports (via the function identifier);B_07.01— services supporting a critical or important function are assessed (risk, substitutability, etc.).
For the overview of templates and their links, see the 15 templates of the register.
Common errors
- a function identifier used in
B_07.01but missing fromB_06.01(orphan reference); - a service linked to a critical function in
B_02.02but without an assessment inB_07.01; - criticality that is unjustified or inconsistent across entities in a multi-LEI group.
Check functions ↔ services ↔ assessments consistency
DoraReady verifies that every function identifier, service reference and assessment points to an existing record, among the EBA's 116 validation rules, and generates the xBRL-CSV package. Everything runs in your browser: your data never leaves your machine.
Run the free diagnosticFrequently asked questions
What is the exact definition?
Where do I declare it?
B_06.01, service-to-function link in B_02.02, assessment of critical services in B_07.01.