Which of the ESA's checks we replay, and which we do not
Generated from the engine on every build — this page cannot say a number the code does not implement.
The European Supervisory Authorities publish 120 validation rules for the Register of Information. Obligia replays 113 of them — every rule that can be evaluated before a filing leaves your building.
The remaining 7 are listed below with the reason for each. They are not a backlog. Four of them cannot be evaluated by any tool outside the receiving authority, or have no subject in a DORA register at all; the rest we decline to count for reasons we would rather explain than hide.
Where the 120 rules apply
The catalogue mixes two questions: whether the register is complete, and whether the file that carries it will be accepted. They are worth separating — the first is the one you are buying.
| What it covers | Replayed |
|---|---|
| What the register contains Cross-references between tables, mandatory fields, critical-function consistency — every rule that decides whether the register itself is complete and coherent. | 71 / 71 |
| How the values are written Data types, closed lists, cardinalities: the rules the data model imposes on every cell. | 12 / 12 |
| The identifiers LEI and EUID: structure, check digits, consistency. The two not covered are the live lookups the ESA marks «do not run». | 6 / 8 |
| The file and its transport The package, its name, its structure and its encoding. The five not covered are transport rules, or have no subject in a DORA register. | 24 / 29 |
Every rule that decides whether the register itself is complete and coherent is implemented. Not one is missing.
Only the receiving authority can evaluate these
They compare your file against something we cannot see: the channel it was sent through, and every filename you have submitted before. No tool outside the authority's own systems can check them — including ours, and including anyone else's.
| Rule | Official wording (ESA catalogue, English) |
|---|---|
| 107 | For CA submitted reports, the submission path country must match the filename country code |
| 110 | Each submitted report filename must be unique - duplicate filenames are not allowed |
Nothing to check in a DORA register
They constrain closed tables. Every template in the Register of Information is an open table, so these two rules have no subject here. We could implement them in an afternoon and count them; the check would do nothing, and the figure would be one better and one less true.
| Rule | Official wording (ESA catalogue, English) |
|---|---|
| 803 | For closed tables, all the row identifier must match those in the dpm |
| 804 | For closed tables, No row identifier can be reported twice |
The ESA marks them «do not run»
Both require a live lookup — a country code against GLEIF, an EUID against BRIS — and the official rule catalogue marks both as not to be executed. Obligia does offer an on-demand LEI check inside the product; counting it here, against a rule the regulator says not to run, would be inflating the figure from the other direction.
| Rule | Official wording (ESA catalogue, English) |
|---|---|
| VR_16 | Code needs to be a valid one according to the GLEIF database |
| VR_78 | EUID code needs to be a valid one according to the BRIS |
Only meaningful at the moment of filing
The reference date cannot be in the future. We check it — in the free verifier, where a file is about to be submitted — and deliberately do not block on it at export: a register prepared before its own period has closed is a legitimate draft, and refusing to export it would break real work to make a number look better.
| Rule | Official wording (ESA catalogue, English) |
|---|---|
| 111 | Reference date in the filename cannot be in the future |