The Bank of England’s new Future Banking Data (FBD) programme has released its first major deliverable, Consultation Paper CP21/25. It proposes a targeted simplification of the regulatory reporting framework to reduce the administrative burden for UK banks, building societies, and investment firms.
This is a significant milestone. The FBD programme integrates two key workstreams: the Banking Data Review, which focuses on what data is collected, and the Transforming Data Collection (TDC) initiative, which focuses on how it is collected. CP21/25 is the first tangible output of this unified approach, but a tight deadline means firms must adapt quickly.
In this blog, we’ll cover what the PRA is proposing, what it means for firms, and the priorities to focus on ahead of implementation.
Proposed changes to PRA CP21/25 regulatory reporting
The consultation sets out three main areas of change:
- Deletion of 37 Templates: The proposal is to cut 34 Financial Reporting (FINREP) templates, two Common Reporting (COREP) templates, and the PRA 109 OCIR template. This represents around a tenth of all regulatory reporting templates and signals a move toward a UK-tailored rulebook where reporting is justified by current supervisory value, not legacy scope.
- Consolidated Rulebook: All FINREP rules will be brought together into a single chapter in the PRA Rulebook. This leverages insights from the TDC initiative to modernise reporting instructions and reduce interpretation costs.
- Aligned Remittance Dates: FINREP remittance dates will be aligned to business days, removing friction from calendar mismatches and simplifying the year-end close process.
The PRA estimates these changes could save the banking sector around £26 million a year. The consultation is fast approaching, closing on 22 October 2025 and implementation is set for a year-end changeover. Firms must act fast.
CP21/25 analysis: Implications for the PRA’s regulatory strategy
CP21/25 feels like a deliberate first step in the long complex journey to reduce reporting burden, explicitly anchored to the PRA’s secondary competitiveness and growth objective. It aims to make cost reductions with a clear commitment to getting “the right data” efficiently, rather than pursuing cost-cutting alone.
The PRA approach seems to be adopting a "test-and-learn" style of policy execution. This is not a one-off exercise but the start of a series of targeted reforms. The approach (deleting low-value, often EU-inherited templates first) allows the regulator to build evidence and industry feedback before moving to more complex changes in future phases.
Market implications: How PRA CP21/25 affects banks and building societies
The one-month consultation and year-end implementation window is very short and challenging. Firms that can pivot quickly to retire scope and adapt calendars will harvest savings sooner and reduce their operational risk.
Key areas of focus should include:
- Modernisation and rationalisation of regulatory reporting: Prepare for clearer, consolidated instructions in the PRA Rulebook, ensuring internal taxonomies are updated accordingly.
- Data lineage and change control across FINREP and ICAAP: Map dependencies across MI, risk, ICAAP, and stress testing to avoid data gaps and downstream disruption.
- Technology alignment with vendor taxonomy updates: Coordinate internal plans with vendor updates to prevent year-end bottlenecks.
Next steps for PRA CP21/25 and the Future Banking Data 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.
In parallel, firms should:
- Monitor related consultations: Upcoming changes to statistical reporting and other collections will provide early indicators of how far simplification could extend.
- Assess long-term implications: CP21/25 is positioned as an initial phase. Future stages are likely to revisit more complex reporting requirements, meaning firms should build flexibility into their data and reporting infrastructure now.
- Engage with the consultation: With the window for feedback closing on 22 October 2025, there is limited time to influence how proposals are finalised. Early engagement can help firms surface practical challenges and shape industry-wide responses.
By taking these steps, firms can move beyond compliance to position themselves for the efficiencies promised by a more streamlined, UK-specific reporting framework.
How Jaywing supports firms responding to PRA CP21/25
Our regulatory risk and data specialists work with firms to manage regulatory change. The PRA estimates CP21/25 could deliver cost savings of around £26 million across the sector. By helping you adapt your reporting processes and align your frameworks, we can support you in realising your share of those savings while ensuring you remain compliant and inspection-ready. Get in touch to see how we can support you.