CP21/25: PRA Consultation on Deleting Reporting Templates – What It Means for Your Bank
Overview
The Prudential Regulation Authority (PRA) has released Consultation Paper CP21/25 as part of its Future Banking Data (FBD) review. The proposals aim to simplify regulatory reporting, reduce unnecessary costs, and make the framework more proportionate.
In short: fewer templates, less duplication, and sharper focus on information that genuinely supports supervision.
Implementation Timeline
Consultation closes: 22 October 2025
Final rules take effect: 31 December 2025 (in time for the Q4 reporting date)
This tight timeframe means banks will need to review and update their reporting processes quickly.
Templates Proposed for Deletion
The PRA proposes to remove:
2 Common Reporting (COREP) templates
PRA109 (Operational Continuity)
34 Financial Reporting (FINREP) templates
COREP:
C 05.01 – Transitional provisions
C 05.02 – Grandfathered instruments
PRA Template:
PRA109 – Operational Continuity in Resolution
(This template only applies to firms receiving critical services and either total assets above £10bn, safe custody assets above £10bn, or sight deposits above £350m. Smaller firms were not in scope.)
FINREP:
A total of 34 FINREP templates are proposed for removal.
For small- and medium-sized banks (total assets below £5bn), only one FINREP template is directly affected:
F 09.01.1 – Off-balance sheet exposures: loan commitments, financial guarantees and other commitments given
The remaining 33 templates do not apply to smaller firms. Still, this is a welcome simplification, providing clearer scoping.
Clarification of FINREP Scope
The proposals also refine FINREP classifications. The PRA is introducing clearer categories, including:
FINREP firms – Banks that must submit the full set of FINREP templates.
Reduced FINREP firms – Smaller banks that only need to submit a cut-down set of FINREP templates.
IFRS firms – Firms that prepare accounts under UK-adopted international accounting standards.
Opt-in IFRS 9 firms – Firms that use UK GAAP but have chosen to apply IFRS 9 accounting rules.
Large IFRS firms – IFRS firms with total assets > £5bn.
Large Opt-in IFRS 9 firms – Opt-in IFRS 9 firms with total assets > £5bn.
This change should help firms better understand which templates apply to them, avoiding unwarranted reporting burden.
Consolidation of FINREP into the PRA Rulebook
The PRA proposes to consolidate FINREP requirements into a single, coherent section of the PRA Rulebook. Currently, they are split across the Regulatory Reporting and Reporting (CRR) parts, which makes them complex and fragmented. By merging them, the PRA aims to reduce interpretative burden, improve clarity on scoping, and help firms avoid unintentional overreporting.
Full List of FINREP Templates Proposed for Deletion
| Code | Title |
|---|---|
| F 09.01.1 | Off-balance sheet exposures: loan commitments, financial guarantees and other commitments given |
| F 09.02 | Loan commitments, financial guarantees and other commitments received |
| F 10.00 | Derivatives – trading and economic hedges |
| F 12.02 | Transfers between impairment stages (gross basis presentation) |
| F 13.01 | Breakdown of collateral and guarantees by loans and advances other than held for trading |
| F 13.02.1 | Collateral obtained by taking possession during the period (held at the reference date) |
| F 13.03.1 | Collateral obtained by taking possession accumulated |
| F 15.00 | Derecognition and financial liabilities associated with transferred financial assets |
| F 16.02 | Gains or losses on derecognition of financial assets and liabilities not measured at fair value through profit or loss by instrument |
| F 16.07 | Impairment on non-financial assets |
| F 16.08 | Other administrative expenses |
| F 18.01 | Inflows and outflows of non-performing exposures – loans and advances by counterparty sector |
| F 19.00 | Forborne exposures |
| F 21.00 | Tangible and intangible assets: assets subject to operating lease |
| F 23.01 | Loans and advances: number of instruments |
| F 23.02 | Loans and advances: additional information on gross carrying amounts |
| Code | Title |
|---|---|
| F 23.04 | Loans and advances: additional information on accumulated impairments and accumulated negative changes in fair value due to credit risk |
| F 23.05 | Loans and advances: collateral received, and financial guarantees received |
| F 23.06 | Loans and advances: accumulated partial write-offs |
| F 24.01 | Loans and advances: inflows and outflows of non-performing exposures |
| F 24.02 | Loans and advances: flow of impairments and accumulated negative changes in fair value due to credit risk on non-performing exposures |
| F 24.03 | Loans and advances: inflow of write-offs of non-performing exposures |
| F 25.01 | Collateral obtained by taking possession other than PP&E: inflows and outflows |
| F 25.02 | Collateral obtained by taking possession other than PP&E: type of collateral obtained |
| F 25.03 | Collateral obtained by taking possession classified as PP&E |
| F 26.00 | Forbearance management and quality of forbearance |
| F 41.01 | Fair value hierarchy: financial instruments at amortised cost |
| F 42.00 | Tangible and intangible assets: carrying amount by measurement method |
| F 43.00 | Provisions |
| F 44.01 | Components of net defined benefit plan assets and liabilities |
| F 44.02 | Movements in defined benefit plan obligations |
| F 44.03 | Staff expenses by type of benefits |
| F 45.03 | Other operating income and expenses |
| F 47.00 | Average duration and recovery periods |
For more information, please contact:
Josh Nowak
Managing Director
Risk & Regulatory Consulting
T: +44 (0)7587 720 988
E: josh.nowak@katalysys.com
Manish Patidar
Director
Risk & Regulatory Consulting
T: +44 (0)7766 001 643
E: manish.patidar@katalysys.com