The PRA set out its strategic approach to reforming banking data collections in Discussion Paper 1/26 (DP1/26) - Future Banking Data (FBD) published on 4 February 2026.
DP1/26 is part of the PRA’s FBD programme to reduce regulatory reporting costs for banks while improving the relevance, quality, and timeliness of data.
The PRA highlights where the current data estate is complex, costly and sometimes unclear, and proposes principles and priorities for pragmatic, incremental reform.
In this article
What does this mean?
FBD is designed to deliver tangible cost reduction - consistent with the PRA's secondary competitiveness and growth objective - by anchoring reporting in proportionality: collecting only what is needed, scaled to the risks each firm poses, without compromising supervisory effectiveness.
The PRA seeks feedback on six questions covering the appropriateness of the PRA's proposed principles and trade-offs, how firms weigh incremental versus wholesale reform, which reporting topics to prioritise, the biggest drivers of reporting cost, and the direction of the FBD programme. Responses will be essential in shaping the PRA's thinking and future reform roadmap.
The role of banking data
Datasets are fundamental to the PRA's ability to deliver its statutory objectives, underpinning effective supervision, financial stability, and decision-making across policy and operational areas.
DP1/26 sets out the role of banking data at the PRA through six distinct use cases:
Firm supervision draws on regulatory returns, management information and non-Rulebook collections to support risk assessment and benchmarking, scaled proportionately by firm size.
In crisis supervision, the PRA prioritises timeliness over comparability, with lessons from past events pointing to the value of a pre-prepared 'data playbook'.
- Cross-sectional analysis uses consistent returns such as Common Reporting (COREP) and Financial Reporting (FINREP) to benchmark exposures across firms and sectors - for example, monitoring country-level exposures following geopolitical events.
- Policy and research uses data across the full policy cycle, from risk identification to evaluation.
- The Stress Test Data Framework (STDF) provides granular, forward-looking assessments under stress.
- Mortgage data - spanning over 50 collections across the BoE, PRA and FCA - supports monetary policy, financial stability, supervision and resolution planning.
What is driving burden and complexity
The PRA’s banking data estate has grown over time. It spans more than 400 templates with overlapping themes.
Capital appears in around 120 templates, across COREP, FINREP, legacy Financial Services Authority and PRA templates, and stress testing datasets. Credit risk is covered in over 100 templates across PRA, wider Bank and FCA-received data.
Looking at monthly submissions alone, some firms face deadlines on 15 different business-day dates - with additional collections measured in calendar days - creating operational peaks that firms have flagged as a source of significant friction. Meanwhile, the 2024 cross-firm liquidity review showed the PRA drawing on FINREP, COREP, annual reports and voluntary returns simultaneously just to assess risk in banks' liquid asset buffers - illustrating how overlapping data demands compound the reporting challenge.
The PRA notes duplication is relatively uncommon, but similar underlying data are often cut differently across collections. The charts show that the largest data volumes are in PRA110 and the STDF, with 201 million and 113.3 million data points collected, respectively, in 2024. The reporting burden is also highly concentrated: Global Systemically Important Banks submit around 5.6m datapoints annually, versus around 0.1m for smaller firms.
The PRA also points to operational friction:
Multiple submission channels (Bank of England Electronic Data Submission, RegData and emailed spreadsheets).
Different file formats (XBRL, XML and Excel).
Inconsistent remittance date conventions and quarter-end peaks.
The direction of travel
DP1/26 signals further rationalisation after the first phase of template deletions implemented from 31 December 2025. Likely target areas may include legacy FSA templates, overlapping capital and credit risk collections (currently spanning 120+ and 100+ templates respectively), and fragmented mortgage data reporting.
It also links to broader proportionality work, including ‘Strong and Simple' reporting reductions for Small Domestic Deposit Takers. The PRA expects reform to be pragmatic and incremental, rather than ‘big bang’. It wants better evidence on the steady-state cost of reporting and the one-off cost of change, to sequence reforms more effectively.
Proposed principles and key trade-offs
The PRA proposes four guiding principles: objectives-driven collection, ‘collect once and well’, easier supply of high-quality data, and keeping collections fit for purpose over time.
It also sets out trade-offs it expects to navigate, which will shape future reforms:
Timeliness vs comparability (especially in crises).
Standardisation vs flexibility, including definitions and dictionaries.
Granular vs aggregate reporting, with reuse benefits but higher build costs.
Regular vs ad hoc requests, and whether repeated non-Rulebook returns should move into rules.
UK tailoring vs international alignment for cross-border firms.
Data continuity vs decommissioning, balancing research value with burden reduction.
Minimising rework vs delivering improvements sooner, recognising that a roadmap that accepts some rework may enable firms to gain benefits more quickly.
What do firms need to do?
Consolidate reporting ‘data demand’ into a single view with clear owners, source systems, key transformations and known duplication/re-cutting points.
Map your current PRA reporting footprint, including Rulebook returns, non-Rulebook requests and related management information feeds.
Quantify reporting and change costs, and identify the biggest drivers of effort and data quality risk across themes, frequencies and systems.
DP1/26 is an early engagement step in what the PRA expects to be a multi-year reshaping of prudential reporting. The PRA explicitly positions this as a collaborative exercise, seeking firm input to co-develop the reform roadmap.
This means moving beyond template-by-template comments. Banks should build a consolidated view of ‘data demand’ across PRA110, COREP/FINREP, PRA-specific templates, stress testing and recurring ad hoc requests. They should then link each demand to upstream data sources, transformations, controls and accountable owners. This will help identify where the same underlying data is being reworked into different cuts.
Banks should also run a reporting cost-driver diagnostic now (data volume/frequency, instruction complexity, validation/coherence effort, definition divergence and data-dictionary gaps) to evidence their response to the PRA and help steer the FBD programme towards the biggest pain points.
Operationally, firms should be clear on how the PRA’s trade-offs may affect them. If the PRA pushes for greater standardisation through a data dictionary, banks should set out where robust definitions already exist and where gaps remain. If the PRA moves toward more granular collections in targeted areas, firms should evidence build effort, ongoing run-cost, and testing and reconciliation impacts. Where the PRA’s issue is clarity, firms should point to specific instruction pain points, including legacy EU references and challenges in interpreting reporting perimeters and thresholds.
Banks should also assess how resilient their reporting is under stress. DP1/26 notes that in crises, timeliness becomes critical and data needs may shift quickly. Firms should test whether their operating model can accelerate production, draw on management information where appropriate, and maintain accuracy under pressure.
Looking ahead, while DP1/26 does not explicitly address crypto-assets, its focus on adapting to technological change and filling data gaps suggests this may be a key area of supervisory attention in the future. Banks should consider how the proposed principles could be applied to future reporting for emerging asset classes, like crypto. This ensures feedback is forward-looking and helps shape a data strategy that is built for the future.
DP1/26 also references Bank research linking granular mortgage data to climate transition exposure through property energy efficiency. While disclosure is not within scope, the PRA notes it will consider knock-on consequences - firms may use this consultation window to help shape how climate and ESG data definitions evolve within the prudential reporting framework.
“The PRA's Future Banking Data discussion paper is a welcome opportunity to reshape a reporting estate that has grown increasingly complex and costly. The industry needs to reflect on both the guiding principles and the trade-offs the PRA has highlighted, adopting a strategic multi-year view. Getting the sequencing right will be key: delivering tangible burden reduction without compromising supervisory insight.”
Peter El-Khoury
Partner, PwC
Next steps
DP1/26 closes on Tuesday 5 May 2026. The PRA will use responses to develop a roadmap with industry for pragmatic, incremental reforms, including further template rationalisation, improved instructions and a potential data dictionary approach.
Contacts
Peter El Khoury
Hugo Rousseau
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