CP21/25 – Future banking data review: Deletion of banking reporting templates

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Responses are requested by 22 October 2025.

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Reporting, Disclosure and Data Strategy Team
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1: Overview

1.1 The PRA collects a wide range of regulatory data from firms to support the delivery of its statutory objectives. These data are required for the PRA to be able to supervise firms effectively, assess risks to financial stability, and inform policy development. To support these functions, the PRA needs timely, high-quality, and relevant data. However, producing such data can be costly for firms, making it essential that reporting requirements are proportionate.

1.2 The PRA is reviewing its approach to 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 data collection.

1.3 This consultation paper (CP) sets out proposals to delete certain regulatory reporting requirements for banks. The proposals are an initial set of targeted deletions of whole reporting templates as a first deliverable from the FBD programme in line with plans set out in the PRA's recent consultation on the annual funding requirement (PRA Levy) CP8/25 - Regulated fees and levies: Rates proposals for 2025/26. This initial phase is expected to deliver a reduction in reporting burden for banks of approximately £26 million annually.

1.4 These initial proposals focus on Financial Reporting (FINREP) templates as a relatively standalone set within the broader reporting environment, paving the way for further streamlining across other collections in future phases. Insights from this phase will inform future workstreams that are likely to be more complicated, as they are likely to also involve partial deletions and reconfigurations of existing data collections in order to achieve further net reductions in firms' overall reporting burdens.

1.5 The PRA will set out its thinking on Future Banking Data in a Discussion Paper later this year, with the intention to deliver a series of pragmatic and incremental changes to reporting - each of demonstrable benefit - over the coming years. The PRA will seek views from firms to help shape the direction and implementation of these changes.

Proposals in this CP

1.6 In this CP the PRA proposes to delete 34 FINREP reporting templates. This represents around a third of all FINREP collections, and around a tenth of all regulatory reporting templates. These collections are either duplicative of other collections or information sources, or misaligned with current supervisory and policy needs.

1.7 The CP also proposes amendments to the PRA Rulebook to consolidate FINREP requirements into a single, coherent chapter, reducing interpretative effort and supporting more consistent compliance.

1.8 In addition to the FINREP deletions, the PRA proposes to delete three further templates: two Common Reporting (COREP) templates and PRA 109 as these have become obsolete and no longer provide sufficient supervisory value.

1.9 The proposal is to delete regulatory reporting that does not materially contribute to the PRA's supervisory and policy work. Therefore this proposal is neutral with respect to the PRA's primary objective of promoting safety and soundness of firms. The proposals would nonetheless support the PRA's secondary competition objective, as well as its secondary competitiveness and growth objective by reducing burden on firms. An effective, efficient, and proportionate reporting framework would enhance the UK's position as a global financial centre.

1.10 In parallel to this CP, the Bank of England is proposing to delete six resolution templates that are either duplicative, no longer needed, or being consolidated into revised MREL templates. Their removal will reduce reporting burden without affecting the Bank's ability to carry out its resolution responsibilities. These proposals are set out in the Bank's separate consultation on COREP13 reporting requirements.

1.11 The policy proposals included in this CP are:

Amendments of FINREP reporting requirements:

• deletion of selected whole FINREP templates;
• consolidation within the PRA Rulebook of remaining FINREP requirements;
• clarification of scoping conditions where current provisions are unclear, duplicative, or inconsistently applied; and
• alignment of reporting remittance dates for FINREP reporting.

Deletion of certain other whole reporting templates:

• deletion of selected templates from COREP and PRA reporting.

1.12 The proposals in this CP would result in changes to the Regulatory Reporting Part and CRR Reporting Parts of the PRA Rulebook (Appendix 1) and supervisory statement (SS) 34/15 - Guidelines for completing regulatory reports (Appendix 2). The templates to be deleted are listed in Appendix 2.

1.13 The CP is relevant to PRA-authorised UK banks, building societies, 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.

Implementation

1.14 The PRA proposes that the implementation date for the changes resulting from this CP would be Wednesday 31 December 2025. This date would facilitate implementation before the Q4 reporting date and yield benefits as soon as is practicable. This date has been chosen to align with the calendar year to avoid transitional complexities.

Responses and next steps

1.15 This consultation closes on Wednesday 22 October 2025. This shorter consultation window is to facilitate implementation at year-end. The PRA invites feedback on the proposals set out in this consultation. Please address any comments or enquiries to [email protected].

1.16 When providing your response, please tell us whether or not you consent to the PRA publishing your name, and/or the name of your organisation, as a respondent to this CP.

1.17 Please also indicate in your response if you believe any of the proposals in this consultation paper are likely to impact persons who share protected characteristics under the Equality Act 2010, and if so, please explain which groups and what the impact on such groups might be.

2: The PRA's proposals

Background

2.1 The banking data reporting landscape overseen by the PRA is extensive, designed to serve multiple supervisory and policymaking purposes. The breadth of these reflects the diverse information needs across the UK's regulatory framework. The FBD programme seeks to take a holistic view of this landscape, with all substantive regulatory reporting requirements - such as financial and regulatory reporting, resolution data, and statistical forms - considered within scope for review.

2.2 The PRA has received feedback that changes to reporting frameworks can introduce costs, particularly where volume and complexity are high. Through the FBD project, the PRA is taking a phased approach to ensure that reporting is targeted and proportionate. The initial phase will focus on targeted deletions of whole templates, aiming to deliver early benefits to firms by streamlining a specific stand-alone regulatory collection.

2.3 The PRA considers the FINREP module to be a suitable candidate to start its review of banking data. FINREP is a large, complex reporting module but with limited interactions with other regulatory collections. FINREP is a framework inherited from the EU which reflected the requirements of 28 member states. The current collections include some data the PRA no longer needs to support its supervisory or policymaking activities.

2.4 The PRA proposes to delete certain whole FINREP templates in recognition in light of a review of its use of the data they contain. In many cases, the information captured through these templates can be sourced through alternative means, including the Whole of Account Reporting (WAR) submissions for larger firms. While the PRA continues to recognise the importance of data on key accounting topics, the design and scoping of the templates proposed for deletion do not provide sufficient supervisory and policy value to justify their continued collection. These proposals aim to reduce unnecessary reporting burden while maintaining the PRA's ability to monitor relevant risks effectively.

2.5 The PRA has also observed that some firms may be reporting more FINREP data than required, as indicated by waiver requests for templates that would not typically apply to them. This suggests that the complexity and lack of clarity of the requirements may be contributing to unintentional overreporting. Firms remain responsible for determining their own regulatory obligations. But by improving the clarity of requirements and improving transparency around FINREP reporting populations, the PRA aims to support firms in navigating these obligations more effectively, which could yield early improvements in efficiency and usability for both firms and supervisors.

Amendments of FINREP reporting requirements

Deletion of whole FINREP reporting templates

2.6 The PRA proposes to permanently delete 34 FINREP reporting templates and disable the associated validation rules. The list of templates proposed for deletion is set out in Annex 2.

2.7 As noted above, the PRA has reviewed the templates within FINREP and assessed that those it proposes to delete do not provide sufficient value to the PRA to warrant their continued collection. A number of these templates are not used in any active supervisory tools or processes, do not relate to material risks to the PRA's objectives, and are not used in policy development and evaluation. While some of these templates do cover areas of potential thematic interest-such as off-balance sheet exposures and forborne loans-they are not suitable for use in their current form due to issues with design, such as the level of granularity. In some cases, these templates duplicate other data sources. A small number of templates are used occasionally to support analysis or research, but the frequency and intensity of use does not justify the burden placed on firms. Overall, the PRA considers that the removal of these templates would not compromise its ability to meet its supervisory objectives.

2.8 The proposed removal of these templates does not alter the PRA's focus on the importance of high-quality accounting in supporting the safety and soundness of firms and the stability of the financial system. The PRA remains focused on the accounting data that it considers most critical. This includes areas where judgement and accounting treatment can have a material impact on capital and risk, such as credit impairments, valuation, and hedging.

2.9 The PRA's supervisory model also places emphasis on engaging directly with firms and auditors to understand these areas in depth. The PRA remains committed to promoting robust accounting practices to ensure that regulatory capital is not based on overly aggressive interpretations of accounting standards.

Consolidation of the FINREP reporting requirements within the PRA Rulebook

2.10 The current FINREP reporting module as contained in the PRA Rulebook is complex and fragmented. FINREP requirements are split across two chapters (Regulatory Reporting and Reporting (CRR)) with reporting obligations that vary based on firm characteristics. This structure reflects a combination of legacy EU requirements and choices made during the process of onshoring that legislation and subsequent incorporation into the PRA Rulebook. The proposals in this CP seek consolidate and simplify the framework where possible.

2.11 The PRA considers that is likely that this complexity contributes to significant interpretative burden in determining applicable reporting requirements. Many firms have to interpret and report under both parts for different parts of their business, which may lead to duplication, operational complexity, and regulatory risk.

2.12 The PRA's analysis suggests that many firms are reporting at the most detailed FINREP level, even when eligible for simplified requirements. In addition, the PRA has observed instances where firms that it would expect to report under more simplified scopes appear to be submitting more templates than necessary, and waiver requests have been received from firms for templates that would not typically be expected to apply to such firms.

2.13 The PRA proposes to consolidate the FINREP scoping provisions into a single, coherent section of the PRA Rulebook. This proposal is intended to improve the accessibility and clarity of the relevant requirements, making it easier for firms to understand whether and how FINREP applies to them. While firms remain responsible for determining the scope of their own regulatory reporting obligations, this proposal seeks to reduce the extent to which a lack of clarity in the rules may contribute to interpretation challenges. The PRA considers that these changes will support firms in interpreting their obligations more effectively, reducing instances of unintentional overreporting and leading to a reduction in unnecessary burden for some firms.

Alignment of reporting remittance dates for FINREP reporting

2.14 Under the Regulatory Reporting Part of the PRA Rulebook, remittance dates are currently aligned to business days. However, firms reporting under the Reporting (CRR) Part are subject to fixed calendar-day deadlines. This inconsistency can lead to operational inefficiencies and confusion.

2.15 The PRA proposes to align all FINREP remittance dates to business days. This change would apply to all firms submitting FINREP templates, ensuring consistency. This change makes no difference to the prudential value of the data collected.

Deletion of certain other whole reporting templates

2.16 In addition to the FINREP deletions, the PRA proposes to delete COREP reporting requirements for firms in relation to two specific reporting templates:

• C 05.01 Transitional Provisions; and
• C 05.02 Grandfathered Instruments.

2.17 Common Reporting (COREP) is a regulatory standard originally developed by the European Banking Authority (EBA) for the submission of prudential data by credit institutions and investment firms. It facilitates supervisory monitoring of firms' capital adequacy and certain risk exposures. The PRA has adopted COREP as part of its regulatory reporting regime to support the effective supervision of firms subject to the UK Capital Requirements Regulation (CRR).

2.18 These templates were originally introduced to capture information on firms' use of transitional and grandfathering arrangements under the CRR. As the relevant transitional and grandfathering provisions have now expired, the templates no longer serve a meaningful purpose in the context of ongoing prudential supervision. The PRA is aware that some firms continue to submit data against these templates, either due to a misinterpretation of the current reporting requirements or the continued use of default reporting models that have not been updated to reflect the expiry of the relevant provisions. The PRA therefore proposes to delete these templates. This proposal is intended to increase clarity, reduce the reporting burden on firms and to support the maintenance of a proportionate and risk-based approach to regulatory reporting.

2.19 The PRA also proposes to delete the reporting requirement for the PRA 109 Operational Continuity in Resolution (OCIR) template. This template has become obsolete following the 2023 OCIR policy revision. It no longer reflects current regulatory expectations and has already been waived in practice.

2.20 These proposed deletions have been identified as part of business-as-usual work, rather than as part of the planned wider review of collections under the FBD. However, they have been included in this CP as part of the first wave of streamlining reporting.

PRA objectives analysis

2.21 The PRA considers that the proposals in this CP would not materially affect the advancement of the PRA's primary objective of ensuring the safety and soundness of firms. Rather, the proposals are considered neutral in relation to the primary objective, aiming instead to streamline reporting without compromising prudential outcomes. The proposed deletions would enable the PRA to remove from the scope of regulatory reporting data collections that do not materially contribute to the assessment of firms' financial soundness. The templates identified for removal have been assessed as offering limited value to the PRA. In many cases, the information is either duplicated in audited financial statements or is now obsolete.

2.22 The PRA has designed these proposals explicitly with the aim of facilitating its secondary objective on the international competitiveness and the growth of the economy in the medium to long term. The PRA considers that by removing templates that are not actively used or that duplicate existing data, the PRA reduces unnecessary complexity and cost in firms' reporting obligations. This initial step serves as a starting point for future reforms, signalling the PRA's commitment to identifying and addressing areas of unnecessary burden. An effective, efficient, and proportionate reporting framework would enhance the UK's position as a global financial centre.

2.23 The PRA has also assessed the proposals in this CP in relation to its secondary objective on effective competition. The specific proposed deletions would predominantly lower reporting burdens and costs for firms that submit FINREP data. While this tends to benefit larger firms which make up the main reporting population for FINREP, it is important to note that other recent changes to reporting under the "Strong and Simple" initiative have already reduced reporting burden for smaller firms. Under the FBD programme, further reductions in reporting are expected to be identified. This work is already underway, focusing on rationalising existing requirements and scoping future areas of reform. As part of this broader effort, careful consideration is being given to proportionality and the potential impacts on competition, ensuring that future changes continue to support a more efficient and effective reporting framework.

Cost benefit analysis (CBA)

2.24 This section sets out the PRA's analysis of the expected costs and benefits associated with implementing the proposals outlined in this CP. The CBA is underpinned by a set of assumptions that reflect the available data and the PRA's proportionate approach to estimating firm-level impacts. The proposals in this CP are expected to deliver a reduction in reporting burden for banks valued at approximately £26 million annually.

2.25 The PRA has analysed the costs and benefits of its proposals using information from a range of sources, including a evidence collected previously to inform the CBA for Basel 3.1 reporting. That assessment reflected data from firms about their actual costs of reporting and of implementing changes to reporting.^{footnote [1]}

2.26 The PRA's CBA panel was consulted in the preparation of this CBA. The Panel provided feedback on the CBA, including recommendations on how best to estimate the potential range of cost savings for firms. Specifically:

• The Panel recommended the CBA clearly sets out the key assumptions underlying the estimate of benefits, for example that the ongoing cost of production of each template is the same. Key assumptions are set out in paragraph 2.47 below.
• The Panel recommended that the CBA should be transparent on how benefits estimates are derived and illustrate more clearly how these vary by size of firm. This is set out in paragraphs 2.36 to 2.40.
• Given uncertainties around the estimates of benefits, the Panel recommended including a range, which is provided at paragraph 2.41.
• The Panel recommended the CBA should assess the plausibility of its estimates by benchmarking them against external sources. This is covered in paragraph 2.46.

2.27 Detailed information on the CBA is provided in Appendix 4.

2.28 The PRA anticipates that future phases of the FBD programme may entail more complex amendments to regulatory reporting, such as template changes or alternative means of collecting data. The CBA estimates included in this CP relate to deletions only, which are simpler. The PRA keeps the underlying inputs and assumptions used for CBA under review and welcomes feedback from firms on the costs of implementing its proposals in order to guide future consultations.

'Have regards' analysis

2.29 In developing these proposals, the PRA has had regard to the FSMA regulatory principles, and the aspects of the Government's economic policy as set out in the Chancellor's recommendations for the Prudential Regulation Committee made in November 2024. In addition to the 'have regards' relating to competitiveness and growth (covered above under objectives), the following factors were significant in the PRA's analysis of the proposals:

1. Proportionality: In developing these proposals, the PRA has had regard to the principle that any burden or restriction imposed on firms should be proportionate to its expected benefits. The PRA considers that continuing to collect data through the templates proposed for deletion would not be justified, as the information is either not used in supervisory assessments or provides only limited value. While a small number of templates may offer some localised insight, the frequency and scale of reporting are not commensurate with their supervisory or policy-making utility. The PRA therefore considers that the proposals in this CP represent a proportionate approach, ensuring that the reporting framework remains aligned with actual supervisory and regulatory needs and does not impose unnecessary costs on firms.
2. Efficient and economic use of PRA resources: The PRA considers that the proposed changes would support a more efficient and economic use of its resources. The proposals would clarify reporting expectations for firms, which may reduce the likelihood of reporting errors and the need for follow-up supervisory engagement. Furthermore, aligning remittance dates to business days is expected to reduce operational complexity, supporting more efficient regulatory reporting processes.
3. Transparency: The PRA considers that the proposals in this CP would enhance the transparency of the regulatory reporting framework. Consolidating FINREP reporting requirements within the PRA Rulebook would improve the coherence and accessibility of reporting obligations. This would assist firms in more easily identifying and understanding the requirements applicable to them. Furthermore, aligning remittance dates to business days would promote greater clarity and consistency across the Rulebook.

2.30 The PRA has had regard to other factors as required. Where analysis has not been provided against a 'have regard' for these proposals, it is because the PRA considers that have regard' not a significant factor for these proposals.

3: Other Legal Requirements

Statutory Duty to Consult

3.1 The PRA has a statutory duty to consult when changing rules (FSMA s138J), or introducing new standards instruments (FSMA s138S). When not making rules, the PRA has a public law duty to consult widely where it would be fair to do so.

3.2 The PRA did not consult its statutory practitioner panel on these specific proposals however it has discussed its broader review of banking data previously with the panel. It has engaged directly with industry on the Future Banking Data programme through other channels, including roundtables with CFOs of the most systemic firms operating in the UK and with representatives of international banks operating in the UK.^{footnote [2]}

3.3 The PRA consulted the CBA Panel in relation to the proposals in this CP. The Panel provided feedback and advised on approaches to gauging the potential range of cost savings estimates for firms. The CBA presented in this CP reflects the Panel's feedback.

Impact on mutuals

3.4 FSMA requires that the PRA assess whether, in its opinion, the impact of the proposed rules on mutuals will be significantly different from the impact on other firms. The PRA considers that the impact of the proposals on mutuals is expected to be no different from the impact on other firms. The reporting requirements apply equally to all firms regardless of legal structure.

Equality and diversity

3.5 In developing its proposals, the PRA has had due regard to the equality objectives under section 149 of the Equality Act 2010. The PRA considers that the proposals do not give rise to equality and diversity implications.