Excel vs. Purpose-Built Tools for DORA RoI: A Comparison

When the European Supervisory Authorities published their DORA Register of Information templates, many compliance officers reached for the familiar: Microsoft Excel. It's free (you're already paying for Office), it's flexible, and everyone knows how to use it.

But here's the uncomfortable truth: 93.5% of firms failed data quality validation in the ESA dry run. Many of them were using Excel.

This article provides an honest comparison between managing your DORA RoI in Excel versus using a purpose-built tool. We'll cover the real pros and cons of each approach so you can make an informed decision for your organization.

The Case for Excel

Let's be fair to Excel. It's not without merit for DORA compliance:

Excel Advantages

No additional cost. If you already have Microsoft 365, there's no incremental spend. For budget-constrained small PIs and EMIs, this matters.

Familiarity. Your team knows Excel. No training required, no learning curve, no new software to deploy.

Flexibility. You can customize formulas, add columns, create your own validation rules, and adapt the templates to your workflow.

Full control. Your data stays in files you own and manage. No third-party dependencies.

ESA-provided templates. The regulators themselves publish Excel templates, so you're starting from an official source.

Excel Disadvantages

No built-in validation. Excel doesn't know the 116 ESA data quality rules. You won't discover errors until the regulator rejects your submission.

Manual data entry errors. Copy-paste mistakes, typos in LEIs, incorrect date formats—Excel catches none of these.

No cross-template consistency checks. DORA's 15 templates are interconnected. Template B_02 references entities from B_01, services from B_04, and so on. Excel doesn't verify these relationships.

Format conversion required. The ESAs expect xBRL-CSV format. Getting from Excel to valid xBRL-CSV is non-trivial and error-prone.

Version control chaos. "DORA_RoI_v3_final_FINAL2.xlsx" sitting in someone's inbox. No audit trail of who changed what.

No LEI verification. You can type any 20-character string into an LEI field. Excel won't check if it's valid, current, or matches the entity.

Scaling pain. Managing 50+ ICT provider contracts in spreadsheets becomes unwieldy fast.

The Case for Purpose-Built Tools

Dedicated DORA compliance tools exist specifically to solve the problems Excel can't.

Purpose-Built Tool Advantages

Real-time validation. Every field is checked against ESA rules as you enter data. Errors are caught before submission, not after.

Automatic cross-template consistency. When you reference an entity in Template B_02, the tool ensures that entity exists in B_01 with matching data.

LEI verification. Integration with GLEIF (the global LEI database) verifies that LEIs are valid, current, and match the named entity.

Correct export format. Generate compliant xBRL-CSV with a single click. No manual conversion, no format errors.

Audit trail. Full history of changes—who modified what, when, and why. Essential for compliance documentation.

Guided data entry. The tool tells you what information is needed, reducing missed fields and improving completeness.

Multi-user collaboration. Multiple team members can work on the register simultaneously without version conflicts.

Purpose-Built Tool Disadvantages

Cost. Purpose-built tools aren't free. Prices range from €500/year to €18,000+/year depending on the vendor.

Vendor dependency. You're relying on a third party for a compliance-critical function.

Learning curve. Some initial time investment to learn the new tool.

Data migration. If you've already started in Excel, moving data to a new tool takes effort.

Side-by-Side Comparison

The Real Cost of "Free"

Excel is free, but failed submissions aren't.

Consider what happens when your DORA RoI fails validation:

1. Notification from your competent authority. You learn your submission has errors.
2. Error identification. You need to figure out which of the 116 rules you violated and where.
3. Data correction. Fix the issues, re-verify cross-template references, regenerate exports.
4. Resubmission. Upload again and wait.
5. Repeat. The ESA dry run showed an average of 1.5-2.3 resubmissions per firm.

Each resubmission cycle costs time and attention from your compliance team. For a small PI with one compliance officer juggling multiple responsibilities, this can mean weeks of disruption.

The Math

Even at the low end, a purpose-built tool often pays for itself in avoided rework.

What the ESA Dry Run Taught Us

The December 2024 ESA dry run report provides concrete data on where firms struggled:

• 86% of errors were missing mandatory information—fields left blank
• 41% of files were rejected for formatting issues before content validation
• 32% of submissions had LEI problems
• 33% of participant queries were about gathering data from ICT providers

These are exactly the problems that purpose-built tools address:

When Excel Might Still Make Sense

We're not saying Excel is never appropriate. It might work for you if:

• You have a very simple ICT landscape. One or two providers, no subcontractors, minimal complexity.
• You have dedicated technical staff who can build and maintain custom validation formulas.
• You already passed the dry run. If your Excel-based process worked, there's less urgency to change.
• You genuinely cannot afford any tool. €500/year is still money, and some micro-entities operate on razor-thin margins.

But be honest with yourself: if you're managing 10+ ICT provider contracts, have subcontractor relationships to document, and need to submit a compliant register by the deadline, Excel is probably not your friend.

Questions to Ask Tool Vendors

If you're evaluating purpose-built tools, here's what to ask:

1. Does it validate against all 116 ESA rules? Some tools only cover a subset.
2. Is LEI verification included? Or is it an add-on cost?
3. What export formats are supported? You need xBRL-CSV minimum.
4. How is pricing structured? Per user, per entity, flat rate?
5. Where is data stored? EU data residency may be required.
6. What happens to my data if I cancel? Can you export everything?
7. Is there a free trial? Test before you commit.

FAQs

Can I start in Excel and switch to a tool later?

Yes, but you'll need to migrate your data. Most tools can import from Excel, though some manual cleanup is usually required. Starting with a tool from day one is simpler.

Are the ESA Excel templates really "not recommended"?

The ESAs have stated that Excel templates are provided for convenience but are "not recommended" for actual submissions due to the difficulty of maintaining data quality and generating correct export formats.

What if I only have a few ICT providers?

Complexity matters more than count. If your three providers include a cloud platform with multiple services, an outsourced payment processor, and a software vendor with subcontractors, you still have significant documentation requirements.

Do I need to report on every IT contract?

No. DORA focuses on ICT services supporting "critical or important functions." But determining what qualifies requires careful analysis—another area where guided tools help.

Conclusion

Excel is a powerful general-purpose tool. It's just not built for DORA compliance.

The 93.5% failure rate in the ESA dry run wasn't because compliance officers are incompetent—it was because the task requires automated validation, cross-template consistency checking, and format conversion that spreadsheets don't provide.

A €500/year investment in a purpose-built tool is almost certainly cheaper than the hidden costs of failed submissions, resubmission cycles, and compliance officer time.