PRA’s CP21/25: A turning point for banking data and reporting governance

The Prudential Regulation Authority (PRA) is accelerating its efforts to simplify and modernise regulatory reporting. Its recent consultation paper 21/25 proposes the deletion of 37 reporting templates, including 34 FINREP templates, two COREP templates, and PRA109. This initiative, as part of the Future Banking Data (FBD) programme, aims to reduce operational burden and improve the efficiency of data collection.

The consultation closed on 22 October 2025, with implementation expected by 31 December 2025, in time for Q4 reporting. The PRA estimates these changes could save the industry around £26 million annually, marking a significant milestone in the broader effort to streamline banking data requirements.

Reasons for these changes

• Simplifies reporting requirements while reinforcing the core objective of ensuring the safety and soundness of firms
• Reduces unnecessary complexity and cost in firms’ reporting obligations, resulting in an effective, efficient, and proportionate reporting framework
• Supports a more efficient and economic use of resources by clarifying reporting expectations for firms, which may reduce the likelihood of reporting errors and the need for follow-up supervisory engagement.

‘Simple’ doesn’t mean ‘easy’

While fewer templates might sound like less work, the opposite is often true. As reporting volumes shrink, the regulatory expectation for data accuracy, timeliness and governance only grows stronger. Firms must now prove that the data behind the remaining templates is trustworthy, reconciled and well controlled.

This is the first phase of a series of reforms under the FBD programme, which will eventually reshape how data is collected, validated, and submitted.

In addition, the Bank of England’s recent roundtable with industry members of UK Finance (‘UKF’) and the Building Societies Association (‘BSA’) highlighted a key theme: “How do firms ensure good governance and data quality on reporting processes while reducing operational burden?”

Alongside this, the PRA’s September 2025 Dear CFO letter on IFRS 9 expected credit loss (ECL) practices reinforces the same message. The regulator expects firms to maintain strong governance, data quality, and model risk management, with progress reviews planned throughout 2026.

Next steps for banks

Together, these developments mark a pivotal opportunity for banks to re-evaluate their reporting requirements across the organisation, including:

• Governance: Are roles, responsibilities, and sign-off processes clearly defined and embedded across reporting requirements?
• Data quality: Are controls robust enough to ensure accuracy and consistency across financial and risk data?
• Technology alignment: Are systems adaptable enough to meet evolving regulatory requirements?

By addressing these questions now, firms can not only meet the immediate requirements of CP21/25 and IFRS 9 feedback but also prepare for the next phases of the FBD programme, which may involve more granular data submissions and digital reporting solutions.

How 4most Can Help

These changes present a real opportunity to simplify and strengthen reporting processes. To support firms, we provide practical workshops and focused reviews that help you:

• Assess maturity of current reporting, governance, and data quality frameworks.
• Identify quick wins for efficiency and compliance.
• Develop a roadmap for sustainable, future-ready reporting processes.

As the PRA redefines the reporting landscape, now is the time for firms to simplify, strengthen, and future-proof their data foundations.

Get in touch if you want to discuss how we can support your organisation’s data reporting strategy – info@4-most.co.uk.