Preparing for BSP’s ITRS: How Banks Can Streamline Reporting

The Bangko Sentral ng Pilipinas (BSP) is entering a new era of regulatory reporting with the full implementation of its International Transactions Reporting System (ITRS) currently slated for June 2, 2025. This API-driven framework, designed to capture and monitor all cross-border transactions, seeks to enhance oversight, streamline data collection and improve the accuracy of cross-border financial reporting from regulated banks.

For banks, compliance with ITRS presents both opportunities and challenges, ranging from integrating multiple data sources to reconciling reports with the BSP’s Financial Reporting Package (FRP v15). Here’s what you need to know about the ITRS and how to successfully navigate its complexities.

The ITRS framework is a comprehensive data collection system that requires all BSP-regulated banks to report cross-border transactions at the individual transaction level. It plays a vital role in improving the accuracy of financial data and supporting the country’s Balance of Payments (BOP) reporting in line with international standards.

As mentioned, ITRS serves two primary functions:

• Monitoring cross-border transactions: By capturing detailed information on peso and foreign-currency transactions between residents and non-residents as well as inter-resident foreign currency transactions, the system advances transparency in the financial sector.
• Strengthening prudential supervision: The BSP uses ITRS data to oversee foreign exchange transactions, assess financial stability risks and support policy decisions.

While ITRS primarily focuses on transaction-level reporting, it also comprises a summary report that tracks banks' daily net on-balance sheet foreign exchange assets and liabilities, along with their overall net foreign asset positions.
 

As part of ITRS compliance, banks must submit a mandatory reconciliation report comparing the ITRS Main Report with BSP's FRP v15. This process helps validate data accuracy and maintain consistency across BSP’s regulatory framework.

The ITRS Reconciliation Report includes 145 line items divided into 69 line items for on-balance sheet FX assets and 76 line items for on-balance sheet FX liabilities. These line items are cross-referenced between ITRS account codes and FRP account codes, supporting alignment across reporting structures.

The reconciliation spans four financial books, requiring banks to validate and compare data across:

• Foreign Regular Book
• Foreign Currency Deposit Unit (FCDU) / Expanded FCDU (EFCDU) Book
• Foreign Office Book
• Peso Accounts Book

Banks must submit the ITRS Reconciliation Report monthly, due on the last working day of the month following the reference period.
 

The implementation of ITRS is part of BSP’s broader shift toward API-driven regulatory reporting, impacting submissions such as the Report on Cross-Border Financial Positions (RCBP), the Report on Electronic Money Transactions and Basel III reporting. Rather than treating these as separate obligations, banks may seek to benefit by standardizing data models across reports.
 

The table below outlines the full list of reports required under the International Transactions Reporting System (ITRS), including their submission frequency and key focus areas.

Following a pilot launch in late 2023, BSP initially planned for ITRS to be fully implemented by April 2024. However, due to emerging technical and report-related concerns, the timeline was extended to allow banks and regulators more time to adapt to ITRS requirements, integrate data sources and ensure compliance with the BSP’s XML-based API submission framework. The testing period now runs through May 2025, with full implementation set for June 2, 2025.

While the delay allows for further preparation, banks should not view it as a reason to slow their ITRS adoption. With increased reporting complexity and the need for cross-referencing with FRP v15, firms that take a proactive approach will be better positioned for a smoother transition when ITRS goes fully live.
 

While ITRS enhances regulatory oversight and data accuracy, its implementation introduces several technical and operational challenges for financial institutions.
 

ITRS requires banks to consolidate transaction data from multiple internal systems while maintaining alignment with FRP v15. Given the volume and frequency of submissions, institutions must establish robust data pipelines that can ingest and validate information in accordance with BSP’s XML schema.
 

Under the new framework, banks must submit reports weekly or monthly, significantly increasing the volume of required disclosures.

Unlike previous reporting structures, ITRS mandates cross-referencing of multiple data sets, making real-time validation essential. Any discrepancies between ITRS and FRP reports could trigger regulatory scrutiny, emphasizing the need for strong internal controls.
 

The shift to API-based reporting represents a major technological change, requiring banks to update legacy systems or implement new reporting platforms.

This transition involves integrating BSP’s XML standards, ensuring compatibility with internal databases and deploying secure submission workflows. Institutions that lack the necessary IT infrastructure or automation capabilities may struggle to keep pace with these regulatory requirements.
 

Beyond technical adjustments, banks must establish clear governance frameworks for ITRS compliance, including internal attestation processes and audit trails. Cross-functional teams (such as compliance, finance, and IT) will need to collaborate ahead of the June 2025 implementation date to ensure timely, accurate submissions.
 

Given the complexity of ITRS submissions, banks should prioritize solutions that simplify data extraction, validation and reporting. A platform-based approach can reduce manual effort while improving reporting accuracy. The right system should: 

• Integrate BSP’s XML schema to facilitate automated submissions.
• Cross-reference ITRS data with FRP v15, offering a side-by-side comparison and automated mapping of account codes between the Financial Reporting Package (FRP) and ITRS reporting.
• Streamline reconciliation processes to reduce errors and regulatory risks, allowing users to view report allocation and reconciliation for each record at a granular data level.

Additionally, by using a platform which can leverage and expand your process for API-based submission, you can gather data more systematically and help futureproof your firm against further regulatory changes.
 

Beyond immediate compliance, financial institutions may seek to align ITRS reporting with their broader regulatory strategy. Look for cloud-based solutions that offer:

• Rapid implementation with pre-configured components aligned with BSP regulations, including XML templates, validation rules and comparative reports.
• Built-in tools to slice, dice and visualize data for enhanced analysis.
• Out-of-the-box data model with built-in validations against regulatory-approved values and ITRS reference libraries.
• Review and validation processes before submission, retaining all intermediary and final data, along with validation rules, to support audit defense.

Banks should start preparing for ITRS well in advance of June 2025. However, rather than treating ITRS as just another regulatory obligation, institutions in the Philippines may wish to view it as an opportunity to modernize their reporting frameworks. A proactive approach helps support compliance while providing long-term advantages in regulatory efficiency.

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