How to find missing fields in a DORA Register of Information

• Package missing. A mandatory cell is empty, a LEI fails the check digit, or two tables disagree. Validators catch this after you have already built the file.
• Contract missing. The value was never in the signed pack, so whoever typed the spreadsheet invented it, left it blank, or copied last year's guess. Validators cannot see that. Only a pass over the documents can.

Letzscale is built for the second problem first: it maps your ICT contracts to the register fields, cites the exact sentence for what is there, and flags Missing — with who to ask — when the data is not in the document.

Why empty cells are not the whole story

The ESAs' dry run made the data-quality problem public: fewer than 7% of nearly a thousand participating firms passed all 116 checks. In Luxembourg, the CSSF has also been clear that validation is being applied to more fields each cycle, so a register that was accepted last year can fail this year without anything changing on your side.

Empty mandatory fields are the easy failures. The expensive ones are fields that look filled and are still wrong: a subcontracting chain that stops at the direct counterparty, a data location that only covers the marketing region, or three Luxembourg entities describing the same provider three different ways.

A practical gap hunt (in order)

1. Run the official validation on the package you have

Before you argue with the content, run the ESAs' data-quality checks (and any national pre-checks your competent authority publishes) against your current xBRL-CSV or workbook. Fix structural errors: filename and timestamp rules, LEI format, coded vocabularies, broken foreign keys between tables.

This is what free and commercial RoI validators are for. Use them. They are not optional.

2. Re-open the source contracts for every critical or important arrangement

For each arrangement that supports a critical or important function, re-read the master, SLA, order forms and annexes. Confirm:

• Unique contract reference and dates
• Provider identity and LEI
• ICT service type and function mapping
• Data and processing locations
• Notice, termination, governing law
• Subcontracting / fourth-party chain

If you cannot highlight the sentence, the field is Missing — even if last year's spreadsheet had a value.

3. Separate not in contract from not yet asked

Many Missing fields are answerable by the provider (subcontractors, secondary processing sites) or by internal owners (which business function the service supports). Put a name next to each gap. A gap list without an owner is decoration.

4. Fix consistency across filers and across tables

Regulators cross-reference. If your ManCo and an affiliate describe the same cloud provider with different LEIs or service types, that surfaces. Align the living register before the annual window, not during it.

5. Re-validate, then file

After content fixes, run validation again. Then submit through eDesk (CSSF), SOFiE / E-File (CAA), or your ECB route.

What Letzscale adds that a validator does not

A validator scores the file you already assembled. Letzscale builds the evidence trail from the PDFs:

• Drop supplier contracts in
• Map against the register fields the regulation asks for
• Every present value ships with a verifiable quote and location in the document
• Every absent value is flagged Missing — not hallucinated
• Ranked gap report tells you what to chase first
• Formatted export feeds your spreadsheet, adviser or GRC

You still run package validation before filing. Letzscale is not a filing tool and not a chatbot.

Try it on one supplier: ranked gap report plus export, free. If we miss a required field that is clearly stated in your contract, our founders manually audit your next three suppliers over the weekend, at no charge.

Who this is for

Mid-sized ManCos, AIFMs, UCITS management companies and payment institutions supervised by the CSSF or the CAA — and consultancies running multiple client registers — who already know the spreadsheet looks full and still do not trust it.

FAQ

Is a blank cell the same as a Missing flag in Letzscale?

A blank cell in the filing package is a validation failure. A Missing flag in Letzscale means the contract pack did not contain the value, so you should not invent one for the package either — you should collect it.

Can I only use a validator and skip contract review?

You can pass structural checks and still file incorrect substance. Supervisors ask for evidence, not only for a green validation report.

Does Letzscale replace Arendt / Formalize-style validators?

No. Use Letzscale to build evidenced rows from contracts; use a package validator before you submit.