GFMA, with the Institute of International Finance (IIF) and the International Swaps and Derivatives Association (ISDA), submitted a joint response to the Basel Committee on Banking Supervision’s consultation on Machine-readable Pillar 3 disclosure.
The response supports the BCBS’ objective to enhance Pillar 3 disclosures through machine-readable formats and agree with the proposed phased approach. The success of the intitiative will depend on the global consistency, interoperability, and clarity of implementation, as experience with regulatory reporting shows that divergent interpretations and firm-specific implementations drive fragmentation and unnecessary cost.
To address this, the response strongly encourages the publication of requirements not only as legal text but also as unambiguous, machine-executable logic, leveraging existing open and market-tested standards such as the Common Domain Model (CDM) and ISDA’s Digital Regulatory Reporting (DRR), rather than creating new frameworks from scratch. This would promote consistent implementation, reduce duplication and long-term maintenance costs, improve data quality, and support integration with other regulatory datasets.
Members also emphasize the importance of avoiding parallel, non-interoperable taxonomies, permitting widely used formats such as Inline XBRL, and ensuring early clarity on scope, taxonomy, and governance, alongside a proportionate and phased implementation timeline.
– 5 March 2026 –
