Let’s break down that integration strategy. What does the first step look like in practice?
Erik Becker: The first step, which is the current phase, is all about eliminating silos within specific regulatory domains. This is at the core of EBA’s proposal: integrating separate requirements such as stress testing, supervisory benchmarking, and selected national data collections more closely into the regular supervisory reporting framework.
FINREP/IFRS 18 is slightly different. It is not primarily about silo elimination, but about adapting reporting to a new accounting structure while applying the same simplification logic.
The same general logic is visible elsewhere. The ECB is moving its Integrated Reporting Framework (IReF) into the realisation phase to consolidate all its statistical reporting, while ESMA starts working to streamline transaction reporting. These are signs that regulators are first tidying up their own houses before broader cross-authority integration becomes possible.
What is the more ambitious Step 2? What are the preconditions for making this happen?
Johannes Turner: The second step is the future vision: eliminating silos between authorities. That is where things get really interesting. The future vision is not just a better-integrated prudential framework, but a world in which data can move more seamlessly between, say, a prudential supervisor like the EBA, a central bank such as the ECB, or a resolution authority like the SRB. The precondition for this is harmonizing how data is, and less of what is, reported. In case of identical requirements, data are shared already today, e.g., EBA ITS in the sequential approach EUCLID between ECB and EBA. Another very positive example shows the SRB, aligning its data sets with frameworks such as AnaCredit.
In case of non-identical but similar requirements, this needs a common technical framework built on concepts such as central data dictionaries, shared data spaces, and frameworks like common data models, e.g., EBA’s DPM 2.0. The groundwork is already being laid, with the European Commission requiring authorities to report on data-sharing plans. Definitely, more granularity will support any data sharing initiative, but we must not forget the importance of “semantic integration” of these different reporting requirements as a basic task, not to multiply efforts and costs.
Regnology has done a tremendous amount of work in these areas to build a central granular data model (RGD) for the integration of regulatory reporting. Also, other jurisdictions in the world follow those developments.