PS27/25 – Future banking data review: Deletion of banking reporting templates

1: Overview

1.1 This Prudential Regulation Authority (PRA) policy statement (PS) provides feedback to responses the PRA received to consultation paper (CP) 21/25 – Future banking data review: Deletion of banking reporting templates.

1.2 The PRA is reviewing its approach to banking regulatory reporting as part of the Future Banking Data (FBD) programme. The FBD programme aims to deliver tangible cost reduction in banking regulatory reporting in line with the PRA’s secondary competitiveness and growth objective, as well as improvements to the relevance, quality and timeliness of data collection.

1.3 The CP set out proposals to delete certain regulatory reporting requirements for banks, building societies, and designated investment firms (hereafter ‘banks’). The proposals are an initial set of targeted deletions of whole reporting templates as a first deliverable from the FBD programme. These initial proposals focused mainly on Financial Reporting (FINREP) templates as a relatively standalone collection within the broader reporting environment, paving the way for further streamlining across other collections in future phases.

1.4 This PS sets out the PRA’s final policy, after considering responses received. It confirms the deletion of the 37 templates identified in the CP and the consolidation of the FINREP scoping provisions into a single section of the PRA Rulebook, also as set out in the CP. It also includes final rules and updated final policy materials. Appendices 2 to 4 set out the PRA policy materials that have been amended, or deleted as part of the final policy as described in this PS.

1.5 This PS is relevant to PRA-authorised UK banks, building societies and PRA-designated UK investment firms, and their qualifying parent undertakings, which for this purpose comprise financial holding companies and mixed financial holding companies, as well as credit institutions, investment firms, and financial institutions that are subsidiaries of these firms, regardless of their location. It is not relevant to credit unions.

Background

1.6 In CP21/25 the PRA proposed to:

• delete 34 whole FINREP templates;
• consolidate within the PRA Rulebook the remaining FINREP requirements;
• clarify scoping conditions where current provisions are unclear, duplicative, or inconsistently applied;
• align reporting remittance dates for FINREP reporting;
• delete three further templates: two Common Reporting (COREP) templates and PRA 109;
• implement these changes on 31 December 2025, to avoid firms having to submit 2025 Q4 data where relevant; and
• amend supervisory statement (SS) 34/14 – Guidelines for completing regulatory reports to reflect these changes.

1.7 In determining its policy, the PRA considered representations received in response to CP21/25. An account of those responses and the PRA’s feedback is set out below.

1.8 In carrying out its policy making functions, in addition to assessing its objectives and cost benefit analysis, the PRA is required to ‘have regard’ to various matters. In CP21/25 the PRA explained how it had regard to the most relevant of these matters in relation to the proposed policy. The final policy is consistent with the proposals in CP21/25. Therefore, the PRA considers that its assessments of objectives and have regards and its cost benefit analysis in CP21/25 remain appropriate.

Summary of responses

1.9 The PRA received 5 responses to the CP. The names of respondents to the CP who consented to their names being published are set out at Appendix 1.

1.10 All 5 respondents supported the proposal to delete the 37 templates. There was a consensus that the proposed deletions would reduce unnecessary burden and help modernise the UK’s regulatory reporting regime.

1.11 Respondents supported incorporating the FINREP requirements into a single chapter of the PRA Rulebook, noting that this measure would simplify the structure of the reporting requirements that remain in the Rulebook. Responses highlighted that the consolidation would contribute to greater clarity and efficiency in reporting processes, facilitating regulatory compliance for both larger and smaller firms.

1.12 Respondents also encouraged the PRA to go further, including reviewing the entire FINREP framework and suggesting other templates that they consider to be low-value, duplicative or outdated, and to apply materiality principles similar to those used in financial reporting. One respondent highlighted that while the deletions are welcome, they deliver relatively limited benefit for smaller firms, reinforcing the case for a more ambitious and systematic review of all reporting requirements.

1.13 Beyond template deletions, respondents expressed strong support for broader reforms under the FBD programme. Two respondents suggested simplifying Pillar 3 disclosures by aligning them with the Basel Committee on Banking Supervision (BCBS) framework, rationalising COREP templates to remove duplication, and moving towards a unified underlying dataset to reduce the need for multiple cuts of the same data. One respondent supported adopting materiality thresholds, streamlining submission formats, and harmonising reporting requirements across prudential and statistical returns. The PRA considers that these comments reflect an ambition shared by the PRA for a more coherent, integrated reporting framework that reduces operational burden while maintaining supervisory effectiveness, but these suggestions were outside the scope of the CP.

Final policy

1.14 The PRA has considered the responses to CP21/25. It is making no further changes to the proposals in the light of suggestions made by respondents, though as noted below some comments will be considered as part of future work under the FBD programme.

1.15 The PRA has made minor clarifications to the drafting of the rules instrument to improve clarity and ensure consistency with the policy intent. These do not affect the substance of the policy or rules.

Implementation and next steps

1.16 The revised rules and the related amendments to SS34/15 – Guidelines for completing regulatory reports will take effect on 31 December 2025 and will apply to reporting reference dates that fall on that day.

Further detail on responses

Consolidation of FINREP requirements

1.17 Respondents supported the incorporation of the FINREP requirements into a single chapter of the PRA Rulebook, noting that this would simplify the structure of reporting requirements remaining in the rulebook The PRA has not made changes to the final policy.

Implementation

1.18 One respondent welcomed the short consultation period and the intention to implement changes in order to avoid the need for 2025 Q4 reporting. In addition, the respondent suggested that, where templates are identified for deletion, the PRA should grant a concession not to report these for reporting reference dates falling end of September 2025. The PRA does not consider this concession to be feasible as the policy finalisation date is after the Q3 remittance date (11 November). The PRA has not made changes to the final policy.

1.19 One respondent, called for harmonisation of reporting requirements and transitional relief in relation to dual UK/EU FINREP reporting, noting that following the deletion of certain FINREP templates in the UK, firms with EU subsidiaries may still be required to report these templates under EU law, resulting in duplication and increased operational costs. The respondent requested that the PRA consider transitional measures to mitigate this burden, such as allowing additional time or flexibility for affected firms during the transition to the new UK reporting framework.

1.20 It is for overseas authorities to determine reporting requirements in their own jurisdictions. The PRA recognises that regulatory divergence between the UK and EU in respect of FINREP may result in additional operational complexity for groups with entities in both jurisdictions. The PRA intends for firms to implement this policy in a way that results in negligible costs, and notes that banks who consider that they may experience operational complexity should engage with their supervisors on a transitional approach.

Cost benefit analysis

1.21 Regarding the CBA, respondents questioned the scale of cost savings estimated for the proposals, commenting that they might be lower than projected due to fixed system costs and the need for transition work. Three respondents argued that while the number of templates would be reduced, the underlying data requirements for other returns might remain unchanged, limiting the immediate impact on operational costs. Two respondents mentioned that, given their specific circumstances, some of the templates were not so relevant for them, so they would not achieve the same level of cost savings.

1.22 While the PRA recognises scope for improvement in CBA relating to reporting, several of these factors flagged by respondents regarding costs were included in the estimates. For example, the cost benefit analysis sought to account for both direct and indirect costs, including system changes and staff training. The proposed deletions mean a smaller number of submissions for firms to update, quality-control, and reconcile in future. In particular, the firm-level estimates presented in the CP are averages based on the reporting population: firms that report relatively more of the templates considered for deletion will receive greater benefit than those who report fewer. Consequently, the PRA does not propose to revise its CBA estimates for this package. Nonetheless, the PRA will explore whether it can refine some of its inputs to CBA relating to data collection following a forthcoming discussion paper (DP) on Future Banking Data, which will set out the principles underpinning the PRA’s approach to reporting with a view to supporting a series of pragmatic and incremental changes to bank reporting over the coming years.

Additional responses outside the scope of the CP

1.23 In addition to the responses to the proposals in CP21/25, respondents provided a range of suggestions on broader topics. A summary of these suggestions related to FINREP and COREP deletions beyond the scope of the proposals in the consultation, wider suggestions on reporting and disclosure, and comments on policy matters other than reporting is set out below.^{footnote [1]} The PRA will consider these additional points as part of future phases of the Future Banking Data programme.

1.24 Additional comments relating to FINREP and COREP deletions included:

• Support for full deletion of C05.01 and C05.02 on the basis these are obsolete, with several respondents noting that the underlying CRR provisions had expired and the templates no longer served a supervisory purpose.
• Streamlining FINREP further to reduce duplication, with respondents noting that these points apply both to FINREP and to wider regulatory reporting requirements.
• Request to update the reporting instructions for the remaining FINREP templates to reflect current accounting standards and UK-specific definitions, ensuring clarity and consistency.

1.25 While several of these suggestions would complement the deletions package proposed in CP21/25, implementing them would require substantial further work to identify and address any dependencies and to prepare the necessary legal instruments. In light of the PRA’s objective to progress the proposed deletions in the CP as quickly as possible, an aim supported unanimously by respondents, the PRA will not be taking these additional recommendations forward at this stage. Nevertheless, the PRA will give due consideration to these suggestions for future deletions phases within FBD.

1.26 Respondents made a range of broader suggestions for further changes on reporting and disclosure. These included:

• Suggestion to review the frequency of all regulatory returns, recommending that some quarterly returns be moved to a bi-annual basis where data does not change significantly.
• Recommendations to consolidate reporting at the highest level of regulatory consolidation (group level), to reduce duplication and operational burden.
• Reviewing the entire FINREP framework for further deletions and simplification.
• Moving towards granular, transaction-level data reporting, particularly for asset classes like mortgages, to replace multiple overlapping templates.
• Withdrawing legacy ad-hoc returns, such as COVID-related or temporary data collections, that are no longer relevant.

1.27 Respondents requested that the PRA review and, where appropriate, delete or rationalise the Pillar 3 templates associated with the FINREP deletions in CP21/25 to ensure consistency and avoid duplication across the reporting and disclosure frameworks. In particular, respondents emphasised that certain FINREP templates proposed for deletion are also referenced in Pillar 3 disclosure requirements, resulting in continued obligations to prepare disclosures based on templates that are being removed from regular reporting.

1.28 Other suggestions from respondents for deletions or rationalisations included:

• Merging similar reports (eg, combining intragroup funding and market infrastructure returns). One respondent recommended merging similar reports such as RFB002 and RFB007 on ring-fencing.
• Removing unnecessary memorandum lines from templates such as PRA110 on liquidity (eg, dynamic monetisation assumptions).
• Aligning disclosure requirements with international standards, particularly for Pillar 3 and BCBS-aligned templates. Firms support aligning disclosure requirements with international standards.
• Providing clearer guidance on materiality thresholds and reporting consolidation at the highest group level.

1.29 Respondents also proposed:

• Streamlining the PRA Rulebook, aligning deadlines, and reducing duplication in Pillar 3 disclosures.
• Clarifying rulebook inconsistencies and ensuring that appendices and rule instruments are fully aligned.
• Harmonising submission platforms (eg, RegData and BEEDS) to reduce operational complexity.
• Establishing industry working groups to optimise regulatory/statistical data collection.

1.30 The PRA notes these suggestions and will evaluate if they are relevant to consider within the FBD programme or other policy initiatives.