What Delegated Regulation 2024/1505 asks critical ICT providers to pay
Once an ICT third-party provider is designated as critical under DORA, the Lead Overseers invoice it for oversight, and Delegated Regulation (EU) 2024/1505 sets how that bill is calculated. Each provider's annual fee is the Lead Overseers' estimated annual oversight costs, adjusted by a turnover coefficient based on the provider's applicable turnover in year n-2, with a floor of EUR 50 000. The fee is invoiced and paid in euro as a single annual instalment, on payment terms of at least 30 days. The regulation supplements DORA Article 43(2), which empowers the Commission to set the amount and manner of payment. It is a cost recovery rule, not a security control. Nothing in it asks a provider to change how it runs its systems, but a provider that treats the invoice as a finance item only will miss the deadlines that matter.
The hard part is usually turnover attribution, not the arithmetic. Applicable turnover means revenue generated in the Union from the ICT services listed in the register of information that the provider supplies to financial entities, so a provider has to map its revenue to those specific services before the coefficient means anything. The provider supports this with audited figures submitted by 31 December each year. If audited figures are not provided, the regulation falls back to broader turnover, which usually raises the coefficient. Providers should confirm with their Lead Overseer which year's figures apply, what form the submission must take, and whether their register entries match the services counted as revenue. Finance, legal and the team that maintains the register of information all need to be in the same conversation.
Decide early who owns the calculation and the audit trail. Map each service in the register of information to its revenue lines, check that the audit firm can certify that mapping in time for the 31 December submission, and diarize the 30 April and 31 December payment dates that apply to your designation timing. Newly designated providers should also ask how the first-year fixed fee and the equal split of fees on the first published list apply to them. Confirm each figure directly with the Lead Overseer, because the regulation sets the method, but the amounts depend on the estimates and designation status that the Lead Overseer holds.
Which providers and revenue lines the fee rules reach
Delegated Regulation (EU) 2024/1505 applies to a small set of ICT third-party providers, and the fee each one pays depends on when it was designated and which revenue it reports. The cards below cover the cases that change the amount, the turnover rules that drive the formula, and the point that financial entities are not the payers.
Providers on the first published list
Providers named on the first published list of critical ICT third-party service providers share the fee equally under Article 4 of the regulation. The equal split means a provider's share does not depend on its turnover in that first cycle. Confirm with the Lead Overseer which list version applies to your organization and whether your designation date places you in this group or in the in-year group.
Providers designated during the year
A provider designated during the year pays a fixed fee for its first year of designation under Article 4, and the payment falls due by 31 December rather than 30 April. Check the designation date in writing, because it determines both the fee basis and the invoice timing. Plan finance and treasury around the shorter payment window.
Voluntary opt-in applicants
A provider that applies voluntarily under DORA Article 31(11) pays a non-refundable EUR 50 000 application fee under Article 4. This fee is separate from the annual oversight fee that follows designation. Before applying, confirm with counsel whether the service portfolio and revenue profile justify the upfront cost, since the fee is not returned if the application is unsuccessful.
Providers without audited figures
Under Article 2, applicable turnover is supported by audited figures the provider submits by 31 December each year. If audited figures are not submitted, the regulation uses broader turnover, which can raise the coefficient and the resulting fee. Build the audit and submission calendar into finance operations, and confirm with the Lead Overseer exactly which broader turnover measure applies.
ICT services that count as applicable turnover
Applicable turnover covers only revenue generated in the Union from the ICT services listed in the register of information ITS provided to financial entities. Revenue from services that a financial entity did not record in its register, or from non-EU activity, falls outside the base. Reconcile the services in your register of information with your revenue ledger so that the reported figure matches what the regulation counts.
Financial entities are not the payers
The fees under this regulation are paid by the designated critical ICT third-party providers, not by the financial entities that use their services. Financial entities keep their own DORA obligations, including the register of information, but they do not invoice or pay oversight fees under Delegated Regulation (EU) 2024/1505. Clarify this point in customer contracts and procurement files so that cost pass-through clauses do not misstate who is liable.
How a provider prepares for its annual oversight invoice
The sequence turns the fee rules in Delegated Regulation (EU) 2024/1505 into a reconciled file: confirmed designation status, a revenue schedule for year n-2, audited figures submitted on time, and a calendared payment. Each step leaves a record that can be checked against the invoice.
Confirm designation status and fee path
Start by confirming with the Lead Overseer which fee path applies. A provider on the first published list is covered by the equal split, a provider in its first year of designation falls under the fixed fee, and a provider under oversight on 1 January follows the standard annual calculation. The provider's legal or regulatory affairs lead should hold the designation letter and the list reference on file. The output is a one-page status note that names the path, the year it applies, and the contact at the Lead Overseer who will issue the invoice. Confirm the exact wording of this status with the Lead Overseer rather than assuming it from the publication date.
Map register-listed ICT services to revenue
Finance and the regulatory team work together to identify the revenue generated in the Union from the ICT services listed in the register of information that the provider supplied to financial entities. Services outside that listing are excluded from applicable turnover, so the mapping must be done service by service, not at group level. Each revenue line should reference the contract or product code and the register entry it corresponds to. The output is a revenue schedule for year n-2 with one row per listed service, its Union revenue, and a reconciliation to the general ledger.
Assess whether broader turnover applies
Determine whether the provider can supply audited figures for the qualifying revenue. If it cannot, the fee is calculated on a broader turnover measure, which is a materially different input and usually a less favorable one. Confirm with the Lead Overseer what form of audited figures it accepts and whether the audit must cover the schedule itself or only the consolidated accounts. The output is a documented decision, signed by the chief financial officer, on which turnover basis the submission will use.
Obtain audited figures for the schedule
Ask the external auditor, or the auditor engaged for the relevant year, to provide figures that support the revenue schedule. The engagement letter should name the schedule, the year n-2 period, and the list of services it covers, so the auditor's work and the submitted figures match. Ask the auditor to confirm in writing which figures are covered and any limitations. The output is an audit-ready extract: the signed schedule, the auditor's report or confirmation, and a trail from ledger to schedule. Start this step early enough that the audit is finished before the 31 December submission date.
Submit audited figures by 31 December
Submit the audited figures to the Lead Overseer by 31 December of each year, as Delegated Regulation (EU) 2024/1505 requires. Use the channel and format the Lead Overseer specifies, and keep the submitted file exactly as sent. Record who submitted it, when, and under what reference. Internal sign-off should be complete before the submission window so that a last-minute correction does not create a version mismatch. The output is a submission record: the transmitted files, the transmission receipt or acknowledgment, and an internal approval record.
Reconcile the invoice against the submission
When the annual invoice arrives, check its calculation against your own record. Confirm the fee path, the applicable turnover figure used, the coefficient applied, and whether the EUR 50 000 minimum annual fee has been applied where relevant. Compare the figures with the schedule and the auditor's extract. Raise any difference with the Lead Overseer in writing, citing the submission reference. The output is a reconciliation sheet signed by finance and regulatory affairs, with each difference either cleared or formally queried.
Calendar the payment deadline and pay
Under Delegated Regulation (EU) 2024/1505, fees are invoiced and paid in euro in a single annual instalment. Providers under oversight on 1 January pay by 30 April, and providers designated during the year pay by 31 December. Check the payment terms printed on the invoice, which must allow at least 30 days, and book the payment with treasury before the date. Keep the remittance advice with the reconciliation sheet. The output is a payment confirmation, filed with the invoice and reconciliation, and a calendar entry for the next cycle.
How each fee component is calculated and what drives it
Most designated providers pay the standard annual fee. Under Article 3 of Delegated Regulation (EU) 2024/1505, the fee starts from the Lead Overseers' estimated annual oversight costs for the provider and is then adjusted by a turnover coefficient. The coefficient uses the provider's applicable turnover in year n-2, so an invoice for a given year draws on figures from two years earlier. The regulation sets a floor of EUR 50 000 for the annual fee.
- Oversight cost estimate: The Lead Overseers produce this figure. The provider does not set it and cannot negotiate it, but it can ask how the estimate was built and how it is allocated across designated providers.
- Turnover coefficient: Applied to applicable turnover from year n-2. Confirm the calculation method against the regulation text and any ESA guidance before relying on a forecast.
- Applicable turnover: Revenue generated in the Union from the ICT services listed in the register of information ITS provided to financial entities (Article 2). Revenue from services outside that register does not count.
- Audited figures: Submitted by 31 December each year. If audited figures are not provided, broader turnover is used, which can change the coefficient.
- EUR 50 000 floor: The minimum applies whenever the calculated amount falls below it.
Before the invoice arrives, reconcile the revenue mapped to register services with finance records, and confirm that year n-2 audited figures were filed on time.
Article 4 of Delegated Regulation (EU) 2024/1505 sets a fixed fee for a provider's first year of designation. The amount is fixed in the regulation, so the provider's turnover does not drive it. A separate rule splits fees equally among providers that appear on the first published list of designated providers. The provider's inputs for this fee are its designation status and the timing of that designation, both of which are set by the ESAs.
- Designation status: The first-year fee applies once a provider is designated. Confirm the designation date and the decision that triggered it.
- First published list: Providers on that list share fees equally under Article 4. Check whether the provider appears on it, because the equal split changes the basis of the invoice.
- Invoice timing: Under Article 5, a provider designated during the year pays by 31 December of that year. A provider under oversight on 1 January pays by 30 April.
- Payment terms: Invoices are issued and paid in euro as a single annual instalment, with terms of at least 30 days.
- Fixed amount: Confirm the exact first-year figure with the Lead Overseer in writing, using the regulation text as the reference.
Before the invoice arrives, confirm the designation date, check the first-list position, and set a payment date that leaves room for the 30-day minimum terms.
Article 4 of Delegated Regulation (EU) 2024/1505 charges a non-refundable fee of EUR 50 000 for a voluntary opt-in application under Article 31(11) of DORA. The provider decides whether to apply, so it controls whether this fee arises at all. The fee is due when the application is made, and it is not returned if the application is unsuccessful or withdrawn.
- Application decision: The provider chooses whether to apply. Assess the business case with legal and compliance advisers before submitting, because the fee is paid regardless of outcome.
- Fixed amount: The EUR 50 000 figure comes from the regulation, so the provider does not calculate it from turnover.
- Non-refundable terms: Treat the fee as sunk once the application is submitted, and budget for it in the application period.
- Relationship to annual fees: Confirm with the relevant authority whether the application fee is invoiced separately from any annual fee and whether it offsets later amounts. Do not assume either answer.
- Payment terms: Confirm the invoice date and deadline with the authority, applying the at-least-30-day terms in Article 5 as the reference point.
Before applying, ask the authority in writing how the fee is invoiced, when payment is due and whether any part of it is credited later.
Why applicable turnover is the number to get right
Applicable turnover is not the provider's total revenue. Under Article 2 of Delegated Regulation (EU) 2024/1505, it means revenue generated in the Union from the ICT services listed in the register of information that the provider supplies to financial entities. Because the fee formula scales with that figure, a provider that reports the wrong base, or cannot prove the base it reports, pays a different annual fee than its position warrants. Finance, legal and the service line owning each contract should agree on this definition before the year-n-2 figures are compiled, not after the Lead Overseers ask for support.
The regulation expects the figure to be supported by audited figures that the provider submits by 31 December each year. If those figures are not provided, the Lead Overseers may use a broader turnover measure. That fallback is the main financial risk in this area: a provider that cannot separate Union revenue from the register-listed services, or cannot tie that revenue to audited accounts, may find itself on a wider base than it would have chosen. Confirm with your auditor, before year end, whether the audited statements can isolate the relevant revenue lines at the level the regulation requires, and what the auditor will need to see.
Disputes are easier to avoid than to win. Three practices help: a segregated ledger or cost centre for register-listed services delivered to financial entities, revenue tagging at invoice level so each billed amount carries a service and jurisdiction code, and a written mapping from each tagged revenue stream to its entry in the register of information. The mapping should be reconciled to the register before submission, so that the same service is described the same way in both places. Teams should also record which judgments they made, such as how shared platform revenue was allocated, so the basis can be defended if questioned.
How a reviewer checks fee calculations and payment records
This table lists the checks a finance reviewer or auditor would run on a Lead Overseer oversight fee, from revenue extraction through payment. Read each row as a test: the evidence column shows what to have ready, and the findings column shows where fee files usually fail.
| Check | Evidence requested | Common findings |
|---|---|---|
| Applicable turnover extraction (Article 2) | Revenue lines tied to ICT services listed in the register of information, with the mapping from ledger accounts to each listed service | Revenue lines not linked to a register entry, or broader group turnover used without explaining why applicable turnover was unavailable |
| Audited figures against statements (Article 2) | Audited financial statements for the year n-2 figure, and the reconciliation from audited totals to the applicable turnover used | Management accounts used in place of audited figures, or totals that do not reconcile to the audited statements |
| Consistency with the register of information | Register of information entries for the provider's arrangements, dated and version-controlled, compared with the revenue mapping | Services billed to financial entities that do not appear in the register, or register entries with no matching revenue |
| Timely submission before 31 December | Submission receipt or confirmation showing the audited figures were delivered by the Article 2 deadline | Figures sent after 31 December, or no proof of delivery to the Lead Overseer |
| Invoice arithmetic against Article 3 | Fee workings showing estimated annual oversight costs, the turnover coefficient for year n-2, and the EUR 50 000 minimum applied where relevant | Coefficient applied to the wrong year, minimum fee omitted, or the invoice total not matching the calculation |
| Payment by the Article 5 deadline in euro | Invoice date, payment terms of at least 30 days, bank record in euro, and the single annual instalment | Payment after 30 April for providers under oversight on 1 January, or payment in a currency other than euro |
| First-year fixed fee and equal split (Article 4) | Designation decision, the first published list, and the fee workings for the first year of designation | Fee for the first year calculated under the annual formula, or the equal split across the first list misapplied |
| Voluntary opt-in fee (Article 4 and Article 31(11)) | Opt-in application record, proof of the non-refundable EUR 50 000 payment, and the date of payment | Opt-in fee treated as refundable, or booked as an annual oversight charge rather than a separate application fee |
Evidence that supports each oversight invoice
Each annual oversight invoice rests on a chain of records: the audited figures behind applicable turnover, the mapping that links ledger lines to register-listed services, and the proof that payment was made on time. Keep these artifacts in one dated file set so the provider can answer an ESA query about any year without rebuilding the figures.
Audited revenue statements
Audited financial statements are the foundation of the turnover coefficient in Article 3. The provider's applicable turnover is the revenue generated in the Union from ICT services listed in the register of information, supported by audited figures. Confirm with your auditor that the statements cover the year n-2 period used in the calculation, and file the signed version rather than a draft.
Year n-2 applicable turnover schedule
This schedule shows how the audited Union revenue was narrowed to services in the register of information ITS. Record each service line, its revenue in euro, and the register identifier it maps to. Keep the schedule under version control so a reviewer can see which assumptions changed between years and who approved them.
Ledger-to-register service mapping
A mapping ties each general ledger account to a register-listed ICT service. Without it, the provider cannot show why revenue was included or excluded. Review the mapping whenever a new contract is signed, a service is retired, or a subcontractor changes, and note the review date and reviewer.
Submission record for audited figures
Article 2 uses broader turnover when audited figures are not provided by 31 December. The submission record proves the date, channel and content of what was sent to the Lead Overseer. Keep the transmission receipt, the file hash and the cover correspondence, because a late or missing submission changes the fee basis.
Invoice and payment confirmation
Fees are invoiced in euro as a single annual instalment, with payment due by 30 April for providers under oversight on 1 January, or by 31 December for providers designated during the year. Store the invoice, the bank transfer confirmation and the reconciliation entry together. Check that the amount matches the calculation and that the payment reference matches the invoice number.
Board or finance sign-off
A named executive or board member should approve the turnover figures and the fee before payment. Record the approval date, the version approved and any open questions. This sign-off shows that management accepted responsibility for the figures, and it gives the next year's team a clear starting point.
What meeting the fee obligation costs beyond the invoice
This table lists the internal and external costs a critical ICT third-party provider may face to support its oversight fee, separating one-time setup from recurring annual work. Read it to see who is paid for each item, what drives it up or down, and what to ask for when scoping the work. The main takeaway is that the fee itself is set by formula, while the surrounding finance, audit and system work is where most of the controllable effort sits.
| Cost component | One-time or recurring | What drives it up or down |
|---|---|---|
| Oversight fee itself | Recurring, one annual instalment | Set by the Article 3 formula from Lead Overseers' estimated costs and the provider's applicable turnover in year n-2, with a EUR 50 000 minimum (Delegated Regulation 2024/1505). The provider does not set it. |
| Audited turnover figures | Recurring, due each year by 31 December | Audit scope and fee depend on how many services and entities feed the Union revenue figure. Ask the auditor to quote the applicable turnover engagement separately. |
| Revenue mapping to register services | Recurring, updated each year | Number of ICT services listed in the register of information and how many customers each serves. Clean register data lowers the time spent reconciling revenue. |
| Ledger tagging of revenue by service | One-time setup, then ongoing upkeep | Chart of accounts design and whether billing systems can tag revenue by service. Tagging at source costs less than reconstructing it at year end. |
| System changes to billing and finance tools | One-time, with occasional maintenance | Age and flexibility of billing platforms, and the need for interfaces to the register. Confirm with your own finance systems team before scoping. |
| Internal finance and legal review | Recurring, around the submission date | Volume of intra-group contracts, currency conversion and the number of entities in the group. Documented procedures reduce repeated review. |
| External advisory review of the calculation | Optional, recurring if used | Complexity of the revenue split and whether an independent check is required by internal governance. Request a fixed-scope quote with defined deliverables. |
What a provider's finance team can run in-house
Most of the fee cycle under Delegated Regulation (EU) 2024/1505 sits comfortably within an existing finance function. Calendaring the annual fee cycle, matching the invoice against the Lead Overseers' notice, reconciling it to the general ledger and releasing payment in euro are routine accounts payable tasks. The regulation fixes the mechanics the finance team has to follow: a single annual instalment, payment terms of at least 30 days, and a payment date of 30 April for providers already under oversight on 1 January or 31 December for providers designated during the year. Finance should build those dates into its close calendar, confirm which date applies to its designation status, and set a internal approval path that clears before the deadline.
Three elements need specialist input, and finance should not treat them as bookkeeping. The first is the revenue mapping across group entities. Applicable turnover counts only revenue generated in the Union from ICT services listed in the register of information, so the team must trace which contracts, legal entities and service lines feed that figure. The second is testing whether a given service falls within register scope, which depends on how the provider describes its services to financial entities. The third is defending an attribution during dispute. Because the fee uses turnover from year n-2 and audited figures submitted by 31 December, the attribution has to be documented and reproducible when the Lead Overseers or auditors ask how a number was built.
A practical step is to ask whether the mapping and scope decisions have been written down with their rationale, who signed them off and which audited figures they rest on. Where the provider lacks in-house capacity for that work, it may bring in an adviser for the mapping and scope analysis, but the choice belongs to the provider. Confirm the exact audit and submission requirements with the Lead Overseers and the regulation text on EUR-Lex before building the process.
Where providers usually miss the fee deadlines and how to close them
Oversight fees under Delegated Regulation (EU) 2024/1505 are calculated from figures a provider must already hold, so most missed deadlines trace back to data that was never organized for the purpose. The four gaps below sit in revenue tagging, audit timing, fee calculation and register accuracy, and each has a closing action that can be finished before the payment window opens.
Revenue not tagged by service
The applicable turnover is revenue generated in the Union from the ICT services listed in the register of information, so a single group revenue line cannot be used as is. Many providers book Union revenue by customer or legal entity, not by service. Close this by mapping each billing code or product line to the register of information entries, and confirm with finance that the mapping covers every Union contract that appears in the register.
Audited figures not ready
The provider must submit audited figures by 31 December each year for the turnover coefficient to be based on them. If audited figures are not provided, a broader turnover measure is used, which can raise the fee. Close this by agreeing the audit calendar with the external auditor early in the year, so the Union service split is covered in scope and the signed figures arrive well before the deadline.
First-year fixed fee mistaken
A provider in its first year of designation pays a fixed fee rather than the standard formula, and teams often apply the turnover calculation anyway or assume the fixed amount continues. Close this by confirming the designation date with the Lead Overseer in writing, recording which fee rule applies for that year, and setting the next year's calculation to start from the applicable turnover in year n-2.
Register data out of step with finance
The register of information and the finance records describe the same arrangements from different angles, and a gap between them makes the turnover figure hard to defend. Contract values, service descriptions and entity identifiers often differ between the two. Close this with a quarterly reconciliation that compares each register entry against the revenue ledger, and assigns one owner to sign off mismatches before the year-end submission.
Questions providers ask about oversight fees and who does the work
How is the oversight fee for a critical ICT provider calculated?
The annual fee starts from the Lead Overseers' estimated annual oversight costs for the provider, then adjusts that amount with a turnover coefficient. Under Article 3 of Delegated Regulation (EU) 2024/1505, the coefficient is based on the provider's applicable turnover in year n-2, so a fee in one year reflects revenue from two years earlier. Applicable turnover means revenue generated in the Union from the ICT services listed in the register of information that the provider supplies to financial entities. The provider submits audited figures for this measure. If it does not, broader turnover is used. The main drivers are the size of the estimated oversight cost, the share of EU revenue tied to listed services, and the quality of the audited figures.
What does the EUR 50 000 minimum fee mean for a provider?
It works as a floor on the annual fee. Under Article 3 of Delegated Regulation (EU) 2024/1505, no provider pays less than EUR 50 000 per year, so a calculated amount below that level is raised to the minimum. A provider with small applicable turnover is the most likely case where the floor applies. Separately, Article 4 sets a non-refundable EUR 50 000 fee for a voluntary opt-in application under DORA Article 31(11). That is a different payment, made when a provider applies to be overseen voluntarily. Confirm with the Lead Overseer which amount applies to your case and how each one is invoiced.
When is the oversight fee due for a critical ICT provider?
Fees are invoiced and paid in euro in a single annual instalment, with payment terms of at least 30 days under Article 5 of Delegated Regulation (EU) 2024/1505. Providers under oversight on 1 January pay by 30 April. Providers designated during the year pay by 31 December. Finance teams should place the invoice cycle in the financial calendar, along with the audited turnover submission due by 31 December each year, since that submission feeds the next fee calculation. Ask the Lead Overseer for the invoice date, payment reference and any required remittance details.
Do financial entities pay the oversight fees for critical providers?
The fee rules in Delegated Regulation (EU) 2024/1505 are addressed to the critical ICT third-party provider, which is invoiced for its oversight. The facts available for this topic do not establish that financial entities pay these fees directly. Financial entities should ask their providers how any oversight cost is treated in contract pricing and check whether their agreements contain pass-through charges. DeployOpen does not set fees, issue invoices or give legal advice on how fees flow into contracts. Confirm the position with legal counsel and the relevant competent authority.
What must a provider submit to the Lead Overseer, and by when?
Under Article 2 of Delegated Regulation (EU) 2024/1505, the provider must submit audited figures that support its applicable turnover by 31 December each year. These figures show revenue generated in the Union from the ICT services listed in the register of information that the provider supplies to financial entities. The underlying service listings come from the register of information, which is set by Implementing Regulation (EU) 2024/2956. If audited figures are not submitted, broader turnover is used, and the result may differ, so the submission is worth preparing early. Confirm the format and submission channel with the Lead Overseer.
Can an implementation partner prepare the revenue mapping for oversight fees?
Yes, within a written scope, an implementation partner can help organize the working files behind the submission. That work includes listing which services appear in the register of information, tracing EU revenue to each service and keeping an evidence trail that finance and the external auditor can follow. DeployOpen plans, implements and documents systems and evidence for compliance readiness. It does not issue audit reports, certify figures or submit turnover on the provider's behalf. The provider's finance team and external auditor own the numbers, and legal owns the interpretation of the Regulation. Ask any partner to state those boundaries in the written scope.
What does the fee work need from finance and legal teams?
The work needs three internal owners, each with a defined task before the submission and payment dates arrive:
- Finance: confirm EU revenue by service line, reconcile it to audited accounts and calendar the 31 December submission and the 30 April and 31 December payment dates.
- Legal: review the Lead Overseer's fee notices, check contract terms with financial entities and confirm how any oversight cost is passed through.
- Operations: keep the register of information entries current, since they determine which services count toward applicable turnover.
Who owns the fee obligation, who prepares the data, and who checks it
The provider owns the fee obligation. Under Delegated Regulation (EU) 2024/1505, each designated critical ICT third-party provider receives an annual fee from the Lead Overseers, calculated from estimated oversight costs and a turnover coefficient based on applicable turnover in year n-2. The finance team confirms the turnover figures that go into that calculation, and the legal team confirms the designation status, the applicable deadlines and the contractual position on invoicing.
- Turnover submission: Finance provides audited figures for revenue generated in the Union from the ICT services listed in the register of information, by 31 December each year.
- Payment calendar: Finance tracks the single annual instalment, paid in euro on terms of at least 30 days, due by 30 April for providers under oversight on 1 January and by 31 December for providers designated during the year.
- Designation events: Legal tracks the first-year fixed fee and the equal split among providers on the first published list.
- Opt-in decision: Legal and the executive team weigh the non-refundable EUR 50 000 application fee under DORA Article 31(11) before any voluntary application.
- Accountability: The management body signs off the submission, so the board needs a documented owner for each step.
Confirm with the Lead Overseer's invoicing contact which entity name, identifiers and remittance details the invoice will use.
An implementation partner can prepare the systems and evidence that the provider uses to produce its turnover figures and its supporting records. The partner works inside the provider's own environment, so the provider keeps custody of the data, the records and the sign-off. The partner does not submit the fee declaration on the provider's behalf unless the provider has delegated that task in writing, and it does not issue audited statements or confirm the fee amount.
- Data mapping: The partner maps ICT services in the register of information to the revenue lines in the general ledger, so the applicable turnover can be traced.
- Reporting pipeline: The partner builds repeatable extracts and reconciliations that produce the year-end figures on a fixed schedule.
- Evidence packs: The partner assembles the documents an auditor will sample, such as contracts, invoices, service descriptions and reconciliation logs.
- Access and logging: The partner configures role-based access to the reporting data and retains logs of changes to the calculation.
- Handover: The partner documents the process so the provider's staff can run it in later years without the partner.
Ask any partner to state in the written scope which tasks it performs, which remain with the provider and which deliverables it will hand over.
The independent auditor checks the financial figures and issues an audited statement. The auditor's output is a report on the figures, not a certificate that the fee is correct, and the Lead Overseers remain responsible for calculating the fee. Because the audit must be independent of the figures under review, the auditor's role is shaped by professional independence rules, so the provider should confirm early what the audit firm can and cannot do for it.
- Audited figures: The auditor provides audited turnover figures that the provider can submit by 31 December, which is the basis for applicable turnover.
- Scope agreement: The engagement letter defines which revenue lines and which ICT services are covered.
- Independence limits: A firm that audits the turnover figures often cannot also design the data pipeline or prepare the evidence it will test, so separate firms may be needed for those tasks.
- Sampling evidence: The auditor selects transactions and contracts from the records the provider supplies, so those records must be complete and traceable.
- Timing: Audit fieldwork must finish early enough for the provider to meet the 31 December submission date.
Before engaging anyone, ask the auditor to confirm in writing which services it will provide and which it cannot provide because of independence rules.
How DeployOpen prepares fee and register evidence
A fixed-scope engagement starts with a written agreement on which entities, revenue lines and register of information entries are in scope for the applicable turnover calculation. DeployOpen maps the ICT services a provider supplies to financial entities onto the matching register entries, so that every figure in the audited turnover submission can be traced to a contract, a service and a customer category. The same mapping shows which revenue falls outside the applicable turnover definition and therefore needs to be excluded or explained. The deliverables are then agreed in writing: the mapping workbook, an evidence pack that links each figure to its source system and approval record, and a process runbook that sets owners and dates for the 31 December submission of audited figures and the 30 April invoice payment deadline under Article 5. Timelines follow from that written scope, and the runbook is designed to be rerun each year.
The client owns the outcomes. Finance and the accountable executives decide which revenue is reported, who signs the submission, and whether the figures are audited, which must be confirmed with the provider's auditor. Legal and compliance decide how the designation status and any contractual pass-through of fees are handled. DeployOpen prepares systems, data extracts, reconciliations and documentation so that the client's own team can produce and defend the figures. DeployOpen does not issue audit reports, attestations or certifications, and independent auditors and the Lead Overseers' processes determine the outcome. Confirm with the relevant ESA or competent authority which documents they expect to receive.
DeployOpen does not publish a price list. A quote follows from the written scope, so ask for the in-scope entities, the number of revenue streams and register entries to be mapped, the systems the data comes from, and whether ongoing support for the annual cycle is included or offered as a separate retainer.
