Every AI agent platform you contract with belongs in your DORA register of information as an ICT third-party arrangement, linked to the functions it supports. Where it supports a critical or important function, the model provider and hosting behind it belong there too, as subcontractors. That is what makes the register useful for spotting concentration.
What does DORA require of the register, in plain words?
DORA (Regulation (EU) 2022/2554), applying from 17 January 2025, requires financial entities to maintain and update a register of information on all contractual arrangements for ICT services provided by ICT third-party service providers. In substance:
- the register is kept at entity level and, for groups, at sub-consolidated and consolidated levels;
- it distinguishes arrangements that support critical or important functions from those that do not;
- it records the providers, the contracts, the ICT services, the functions supported and, for critical or important functions, the subcontracting chain;
- the entity makes it available to its competent authority on request and reports information from it periodically;
- technical standards set out standard templates and identifiers so supervisors can compare registers across entities.
Supervisors use registers, among other things, to see where the sector depends on the same providers. For background, see what DORA is.
Who has to keep it?
Every financial entity in DORA's scope, for every ICT third-party arrangement, regardless of size. Whether a given agent vendor counts as an ICT third-party service provider is covered in are AI agent vendors ICT third-party providers under DORA; a vendor that runs agents for you on its platform almost always does.
How should agent providers appear in the register?
Agent arrangements are layered, and the register should show the layers. Take an illustrative insurer that uses a vendor's claims intake agent. The register should capture:
- The contract with the agent vendor, its dates, governing law and termination terms.
- The ICT service: an agent platform providing claims intake capabilities, with data processing and storage locations.
- The function supported: claims handling, flagged as critical or important if it is.
- The direct provider: the agent vendor, with its identifier.
- The subcontracting chain: the model provider the vendor uses, and the cloud provider hosting inference and storage, each ranked in the chain.
- Assessments: substitutability, exit plan reference and the date of last review.
The fifth item is the one entities miss. Leaving out the model provider makes every agent arrangement look independent, when several may depend on the same model and region. Recording it is what lets you see the concentration discussed in DORA concentration risk and model providers behind agents.
How do you keep the register accurate for agents?
| Requirement | Control | Evidence it leaves |
|---|---|---|
| All arrangements recorded | Agent platforms, model access contracts and agent-related hosting captured at onboarding | Register entries linked to procurement records |
| Functions linked | Each agent capability mapped to the function it supports | Capability-to-function map feeding the register |
| Critical or important flagged | Classification decision recorded per arrangement | Classification rationale |
| Subcontracting chain captured | Contract requires vendor to name model providers and hosting, with notice of change | Subcontractor schedule and change notices |
| Data locations recorded | Processing and storage locations per service | Location fields kept current |
| Kept up to date | Vendor change notices trigger register updates | Update log tied to notices |
| Group consistency | Same provider identified the same way across group entities | Reconciliation at consolidated level |
| Available to supervisors | Register produced in the required templates | Submission records |
Ownership matters as much as content. Procurement usually creates the entry, but procurement rarely learns when a vendor switches model provider or when a business team widens an agent's use into a more important function. Give the agent's business owner a duty to confirm the register entry whenever the agent's capabilities, depth or function change, and give third-party risk the duty to update it when vendor notices arrive.
Accuracy also depends on the contract. If the vendor need not tell you when it changes model provider, your register will drift. The contract position is covered in DORA makes agent providers your ICT third parties.
What will a supervisor ask?
- Show us every register entry for AI agent services.
- Which model providers appear in your subcontracting chains, and for which functions?
- When did your vendor last change model provider, and when did your register reflect it?
- Are agent pilots on live data in the register?
- Does the same provider appear consistently across your group entities?
What does the register not cover?
It does not register the agents themselves with a regulator. It is a record of contractual arrangements, not an inventory of AI systems. The EU AI Act has its own registration requirements for certain high-risk systems, which work differently; see do you need to register AI agents with a regulator. The register also does not replace your internal agent inventory, which records capabilities, depth and owners. And it does not assess risk on its own; it is the data your assessments draw on. For the full map, see AI agent regulation mapped to controls.
This is an explanation of the rules, not legal advice; confirm how they apply to you with counsel.
Where Pryme fits
Pryme records each agent capability with the function it serves and the sources and providers it depends on. That gives the agent inventory a clean link to the register, so a change in an agent's use or a provider's set-up shows up in both rather than drifting apart.
Questions people ask
Do free or trial agent tools need to be in the register?
If they provide ICT services under a contractual arrangement, including click-through terms, and are used in the business, they belong in the register. Unapproved tools used on business data are a separate problem to solve.
Should the register record each agent or each contract?
The register is organised around contractual arrangements and the services and functions they cover. Your internal agent inventory should link each agent to the register entry for its provider.
How deep should the subcontracting chain go?
For critical or important functions, capture subcontractors that effectively underpin the service. For agents, that means at least the model provider and the hosting provider.