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

AI Analysis

Executive Summary

The PRA's CP21/25 proposes deletion of 37 banking regulatory reporting templates—primarily 34 FINREP templates representing approximately one-third of all FINREP collections—as the first phase of its Future Banking Data (FBD) programme. This initiative aims to reduce annual reporting burden by approximately £26 million while maintaining supervisory effectiveness by eliminating duplicative, outdated, or low-value data collections.

What Changed

The PRA proposes the following regulatory deletions: FINREP Template Deletions: - Permanent deletion of 34 whole FINREP reporting templates (approximately one-third of all FINREP collections) - Consolidation of remaining FINREP requirements within a single section of the PRA Rulebook - Clarification of scoping conditions where current provisions are unclear, duplicative, or inconsistently applied - Alignment of reporting remittance dates for FINREP reporting Other Template Deletions: - Two COREP templates: C05.01 (Transitional Provisions) and C05.02 (Grandfathered Instruments) - PRA109 Operational Continuity in Resolution (OCIR) template, which became obsolete following the 2023 OCIR policy revision Rationale for Deletions: Templates proposed for deletion either lack sufficient supervis

What You Need To Do

  • *Cease reporting on the 37 deleted templates effective 31 December 2025
  • *Update internal systems and processes to remove validation rules and submission workflows for deleted templates
  • *Revise compliance calendars to reflect aligned FINREP reporting remittance dates
  • *Review Pillar 3 disclosure obligations to identify any continued requirements based on deleted FINREP templates and assess whether disclosure obligations remain despite template deletion
  • *Implement rulebook changes reflecting consolidation of FINREP scoping provisions into the PRA Rulebook
  • *Update supervisory statement compliance in line with amended SS34/15 – Guidelines for completing regulatory reports

Key Dates

September 2025 - CP21/25 consultation paper published
31 December 2025 - Proposed implementation date to avoid firms submitting 2025 Q4 data for deleted templates
8 December 2025 - PS27/25 (Policy Statement) published, confirming final policy

Compliance Impact

Urgency: HIGH

Who is Affected

Banksand medium-sized banks with total assets below £5bn are particularly affected)Building societiesDesignated investment firmsAll firms subject to PRA regulatory reporting requirements under FINREP, COREP, and PRA reporting frameworks

Summary

Consultation paper 21/25

Relevant Firm Types

Bank
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