BoE pushes ahead with banking data reform

What does this mean?

The FBD programme is a multi-year initiative to reform banking data collection. CP21/25 proposes targeted deletions of whole templates that are duplicative, obsolete or provide limited supervisory value. FINREP is the starting point as it is largely self-contained. The consultation does not propose any changes to liquidity reporting at this stage.

BoE resolution data deletions – COREP13

The BoE proposes to delete six resolution templates under COREP13, covering:

• Liability structure (Z 02.00).

• Own funds requirements (Z 03.00).

• Intragroup connections (Z 04.00).

• Major counterparties (Z 05.01, Z 05.02).

• Deposit insurance data (Z 06.00).

These deletions remove around 1,100 data points, which the Bank deems unnecessary or duplicated elsewhere (e.g. in revised MREL templates), with minimal risk to resolution readiness.

PRA CP21/25 proposed deletions

The PRA proposes to delete the following:

• 34 FINREP templates, including those related to:

  • Off-balance sheet exposures (e.g. F 09.01.1, F 09.02).

  • Impairments and forbearance (e.g. F 12.02, F 19.00, F 26.00).

  • Collateral and write-offs (e.g. F 13.01, F 23.06).

  • Staff costs and net defined benefit plans (e.g. F 44.01 to F 44.03).

• Two COREP templates:

  • C 05.01 (Transitional Provisions).

  • C 05.02 (Grandfathered Instruments).

• PRA109 (Operational Continuity in Resolution), now redundant following the 2023 OCIR policy revision.

These templates were found to offer limited supervisory or policy value, with some duplicating Whole of Account Reporting (WAR) or other datasets.

Rulebook consolidation

FINREP obligations sit across multiple parts of the PRA Rulebook. The consultation proposes consolidating them into a single chapter with clearer scoping rules. This aims to:

• reduce interpretative burden

• limit unintentional over-reporting

• ensure proportionality by matching reporting more closely to firm size and complexity.

Alignment of remittance dates

FINREP remittance dates differ depending on whether firms report under the Regulatory Reporting Part or the Reporting (CRR) Part of the PRA Rulebook - with the former aligned to business-day deadlines and the latter to fixed calendar-day deadlines. The PRA proposes to harmonise these approaches by aligning all FINREP submissions to business-day deadlines, aiming to reduce inconsistencies and support clearer reporting.

Impact on risk and resilience

Both the PRA and the BoE assess these deletions as risk-neutral. The templates proposed for deletion do not underpin critical supervisory tools or financial stability assessments. Where needed, resolution information will continue to be gathered through alternative means such as ad-hoc data requests or the Resolvability Assessment Framework.

PRA deletions are estimated to save £26.3m annually (£22.4m–£30.2m), while BoE COREP13 deletions are expected to save £37.7k per firm, or £6.9m industry-wide over 10 years.

What do firms need to do?

These proposals sit within the multi-phase BDR, following initial work as part of the regulators’ Transforming Data Collection programme and Banking Data Review. While this first step focuses on deletions, subsequent phases are expected to represent a more significant review of the reporting landscape.

This is a timely opportunity to assess whether data governance, validation, and technology are robust and adaptable to ongoing change. Firms that approach the BDR strategically - optimising controls, embedding proportionality, leveraging technology, and actively engaging with the PRA and BoE - will be better placed to accelerate their regulatory reporting transformation, realise long-term efficiencies, and align with future supervisory expectations.

Operationally, firms should identify all affected FINREP, COREP and PRA109 submissions and update workflows and governance documentation ahead of year-end implementation. Even where system impacts are minimal, firms should maintain robust audit trails and clear evidence of Board awareness and sign-off. Smaller and mid-tier firms, in particular, should reassess whether their reporting scope appropriately reflects proportionality under the clarified scoping rules.

The scope of the BoE’s resolution proposal is narrower, affecting firms required to submit COREP13 templates. Templates may remain visible in RegData initially; the BoE asks for simple negative filing indicators until systems are updated.

Next steps

The PRA consultation closes 22 October 2025, with rules finalised by year-end and deletions effective 31 December 2025. The BoE consultation closes 21 November 2025, with final deletions effective 1 April 2026. A further PRA Discussion Paper on broader FBD reforms is expected later by the end of the year.