PRA CP21/25: Towards a unified regulatory data framework

The Bank of England’s Future Banking Data (FBD) programme has released its first major output: Consultation Paper CP21/25. It proposes a more streamlined approach to regulatory reporting, aimed at easing the administrative load for UK banks, building societies, and investment firms.

This represents an important development. The FBD programme merges two strands of work: the Banking Data Review (focused on what data is collected) and the Transforming Data Collection (TDC) initiative (focused on how it is collected). CP21/25 is the first visible product of this combined effort — but with a tight timeline, firms will need to adapt quickly.

In this article, we outline what’s being proposed, the implications for firms, and the immediate priorities ahead of implementation.

Proposed regulatory reporting changes in CP21/25

The consultation highlights three main areas for reform:

• Removal of 37 templates: Including 34 Financial Reporting (FINREP) templates, two Common Reporting (COREP) templates, and the PRA 109 OCIR template. This equates to around 10% of all reporting templates, reflecting a shift toward a UK-specific rulebook where reporting is justified by supervisory need rather than legacy requirements.

• Single consolidated Rulebook: All FINREP rules will be combined into a single PRA Rulebook chapter. This draws on lessons from the TDC initiative, helping to simplify instructions and reduce interpretation challenges.

• Alignment of remittance dates: FINREP reporting deadlines will move to business days, reducing issues caused by calendar mismatches and smoothing the year-end close process.

The PRA projects annual sector-wide savings of around £26 million from these measures. The consultation closes on 22 October 2025, with implementation scheduled for year-end, leaving firms little time to prepare.

CP21/25 in context: A staged approach to regulatory change

The paper marks the beginning of what is expected to be an incremental but significant reform process. It is directly tied to the PRA’s secondary competitiveness and growth objective, balancing cost reduction with the ambition to collect “the right data” more efficiently.

The regulator appears to be applying a “test and learn” philosophy. By first removing low-value, often EU-derived templates, the PRA can gather evidence and industry input before attempting more complex reforms in later phases.

Implications for banks and building societies

The short consultation period and year-end transition create a demanding timetable. Firms that can respond quickly will be best placed to realise cost benefits and mitigate operational risk.

Key areas for attention include:

• Modernising and rationalising reporting processes: Update internal taxonomies to reflect clearer instructions in the consolidated Rulebook.

• Data lineage and dependency mapping: Ensure FINREP and ICAAP links across MI, risk, stress testing, and capital planning are well understood to prevent gaps or downstream disruption.

• Technology and vendor alignment: Coordinate implementation with vendor taxonomy updates to minimise bottlenecks at year-end.

What comes next in the FBD programme

Later this year, the Bank of England is expected to publish a Discussion Paper setting out the principles and roadmap for future phases of the FBD programme. This will provide greater clarity on which reporting areas may be prioritised next and how the PRA intends to sequence further reforms.

Meanwhile, firms should:

• Track parallel consultations: Changes to statistical reporting and other data collections will give early signals on the scale of future simplification.

• Build for flexibility: CP21/25 is only the opening phase; future work is likely to tackle more complex reporting areas. Investing now in adaptable data and reporting infrastructure will pay dividends later.

• Respond actively: With feedback due by 22 October 2025, there is a short window to raise operational concerns and help shape the final framework.

By preparing ahead of time, firms can reduce disruption and be better equipped for the efficiencies the PRA is aiming to deliver.