Three of DORA's fields are three facts about a vendor's terms
Your register needs the provider entity that signed, the
governing law's country, and the provider's headquarters country. Your
filing tool gives you the columns. It does not know the answers.
Vannus holds those three facts for 96 AI
vendors, quoted from each vendor's own terms with a source and a date.
The three fields
Field names and descriptions are verbatim from Commission
Implementing Regulation (EU) 2024/2956, Annexes I and II. If you have seen
RT.xx names, those are from the 2023–24 draft and were
superseded.
B_03.02Always, per arrangement.
ICT third-party service providers signing the contractual arrangements for providing ICT service(s)
The record's fieldContracting entity
The legal person named in the vendor's own terms as the party the customer contracts with, quoted verbatim with the source URL and the date the page was read.
Twenty-nine of the vendors on record contract through more than one entity depending on where the customer is incorporated. For those the register needs YOUR entity, not a general one — which is what the paid report resolves.
B_02.02.0120Conditional — critical or important functions.
Country of the governing law of the contractual arrangement
The record's fieldGoverning law
The choice-of-law clause, quoted from the vendor's own terms. The register wants the ISO 3166-1 alpha-2 code for the country that law belongs to; the record gives you the clause it comes from, so the code is checkable rather than asserted.
Mandatory only where the ICT service supports a critical or important function. Whether yours does is your determination, not ours.
B_05.01.0080Always, per provider.
Country of the ICT third-party service provider's headquarters
The record's fieldNot yet held
This field asks for the country of the provider's global operating headquarters, which the ITS notes is usually the country of tax residence. The record does not yet carry a sourced headquarters or parent-control fact for any vendor, so the export leaves it for you to establish rather than filling it from an unsourced catalog flag.
This is deliberately NOT the contracting entity's country. A vendor contracting through an Irish subsidiary of a US parent files the US here — which is exactly why a guess is worse than a blank.
What the record does not answer
Stated plainly, because a mapping that oversells is worse than
no mapping when you are the one filing.
Field
What it asks
Why not us
B_05.01.0020
Identification code (LEI or EUID)
Only LEI or EUID may be used for legal persons, and only LEI for legal persons established outside the Union. The record does not hold LEIs.
B_05.01.0110/0120
Ultimate parent undertaking
Mandatory where the provider is not itself the ultimate parent. The record holds neither the parent's identity nor its identification code yet; the parent relationship is the next fact it needs a registry source for.
B_02.01
Contractual arrangement — general information
Reference number, type, currency, annual expense. These are facts about YOUR contract and exist only in your own records.
None of this is advice. Whether an arrangement
supports a critical or important function — and therefore whether
B_02.02.0120 is mandatory for it — is your determination and
not ours. Vannus is not your lawyer.
Getting the answers
The record is free to read: every determined vendor's page
carries its contracting entity, governing law and control finding, each quoted
and dated. Browse the record.
Where a vendor contracts through more than one
entity — twenty-nine of those on record do —
B_03.02 needs the entity that signed your arrangement,
which depends on where your company is incorporated. The
AI Subprocessor Jurisdiction Report
resolves that per vendor for your own entity, with the clause attached so you
can check the reading.