IReF Is Coming: A New Era for EU Regulatory Reporting?

After years of discussion, the European Central Bank (ECB) has finalized the design and timeline for an Integrated Reporting Framework (IReF). This initiative aims to reduce the reporting burden on banks by eliminating redundant data submissions and simplifying regulatory oversight. The appeal of a singular IReF submission is clear, but what are the trade-offs? And how can banks adapt to this transformative shift?
 

Following the 2008 financial crisis, the scope of the ECB’s regulatory reporting expanded significantly with new mandates such as Common Reporting (COREP), Financial Reporting (FINREP) and Analytical Credit Datasets (AnaCredit). More recently, the European Banking Authority (EBA) introduced an Integrated Reporting System (IRS) for financial, statistical, resolution and prudential requirements, while the ECB is spearheading IReF as a complementary initiative.

The goal of IReF is to balance compliance costs with the benefits of enhanced market stability and security. Since mid-2023, the Eurosystem has been working to define the business and IT aspects of the framework’s implementation. This phase will culminate in the late 2025 release of a detailed implementation plan.
 

Despite IReF’s intent to reduce reporting burdens, banks must still implement new processes and governance frameworks to support compliance. The most significant impact will be the need to source, validate and submit larger volumes of granular data, requiring substantial changes to banks’ data architectures.
 

The IReF rollout follows a phased approach:

• Mid-2023 – 2025: Eurosystem conducts the IReF investigation phase.
• Late 2025: Eurosystem publishes the detailed implementation plan.
• 2028: One-year pilot reporting phase to facilitate the transition.
• Q4 2029: Full adoption and reporting requirements take effect.

Some banks may already have a head start due to similarities between IReF and other regulatory frameworks. Comparable initiatives include:

• Taxonomy-based submissions incorporating a common data dictionary (e.g., Bank of England, Banque de France, Banca d’Italia, Central Bank of Ireland and Australian Prudential Regulation Authority).
• Expanded granular data reporting (GDR) requirements for balance sheets and interest rates (e.g., AnaCredit, BSI, Hong Kong’s HKMA GDR and MIR).
• Data collection transformation strategies (e.g., APRA’s data collection reforms and the Bank of England’s Transforming Data Collection plan).

Scale typically brings with it advantages. Multi-jurisdictional institutions can leverage past compliance efforts to align with IReF requirements, provided they have automated tools to systematically map reporting elements.
 

Simplified reporting isn’t always straightforward, especially when it involves shifting taxonomies. On the one hand, taxonomy-based approaches improve regulators’ ability to validate, reconcile and extract insights from overlapping datasets. On the other hand, unresolved questions create uncertainty for banks.

For instance, how will IReF impact the many institutions that are not globally systemically important banks (G-SIBs) and still need to report data through local central banks? Since local authorities have yet to confirm their implementation approach, there are open questions about how onward submissions to the ECB will function.

Another key challenge is ensuring data quality. In the past, banks could mask inconsistencies within aggregated or adjusted reports. However, as seen with AnaCredit, granular reporting exposes data quality issues, making it critical for institutions to proactively identify and correct anomalies.

Additional concerns in complying with IReF include:

• Compliance costs: Constantly evolving regulations require banks and regulators to continually invest in adapting systems, personnel and operational processes.
• Regulatory overlap: Multiple regulatory agencies and initiatives, from the ECB and EBA to the Single Resolution Board (SRB) and the Banks' Integrated Reporting Dictionary (BIRD), run the risk of redundancy, forcing banks to reconcile and validate the same data across frameworks.
• Ambiguous requirements: Banks often need extensive back-and-forth with regulators to confirm interpretations, which may lead to delays and inefficiencies in compliance.
• Inconsistent data: Different banks may apply varying methodologies to the same rule, reducing data comparability and potentially undermining its value for regulatory oversight.

Regardless of such concerns, banks must start preparing for the phased rollout of IReF. While many already possess the necessary reporting data, its current level of granularity is likely insufficient for IReF’s enhanced balance-sheet statistics and reporting requirements.

Ultimately, IReF is the first step toward a broader, more harmonized regulatory reporting system. By laying the foundation for integrated data management, this initiative is expected to pave the way for future enhancements in financial and statistical reporting across the Eurozone.

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