FSB Modernisation Principles: Principle 8 and the Reporting Burden

On 14 October 2026 the Financial Stability Board (FSB) opened consultation on eight FSB modernisation principles, published as the consultation report Regulatory and Supervisory Modernisation Principles and addressed to the financial authorities of its member jurisdictions. Responses are due by Friday 8 January 2027, and the FSB says the final report will follow in the first half of 2027. One of the eight, Principle 8, deals with regulatory reporting and disclosure head on: requirements should be efficient, necessary and proportionate, and authorities in the same jurisdiction should make best efforts to minimise duplicative information collection.

No template, field or remittance date changes because of this report. The principles are written for authorities, and the statement on the report’s inside cover says FSB activities and decisions are not binding and give rise to no legal rights or obligations. The weight comes from the commitment the report describes: the principles and their preamble are its operative language, which FSB member financial authorities would commit to implement if the report is finalised, each in its own way. The case studies FSB members submitted already include reporting reviews, from the PRA’s Future Banking Data programme to the Bank of Spain’s review of national reporting.

The consultation asks 14 questions, and several of them, on the benefits and risks of modernisation, cliff effects and impact analysis, ask for the kind of evidence a reporting function already holds. The FSB asks respondents to provide evidence or case studies where possible.

Related reading: FSB AI Sound Practices Final Report: A Governance Gap Analysis

Key dates for the FSB modernisation principles consultation

• 9 June 2026: FSB symposium in Basel on modernising regulatory and supervisory frameworks, summarised in Annex III of the report.
• 14 October 2026: consultation report published, together with the 2026 G20 Implementation Monitoring Review report (FSB press release ref. 13/2026).
• Friday 8 January 2027: deadline for responses through the secure online form linked from the FSB consultation page.
• First half of 2027: final report expected, according to the FSB press release.

The report sets no implementation date for authorities. Its third shared understanding says implementation must be consistent with each jurisdiction’s legal framework and circumstances, and the additional comments on the preamble acknowledge that not all jurisdictions will implement the principles in the same way. Any change to a return would therefore run on a domestic authority’s calendar, which the FSB timetable does not fix.

One procedural point comes before any drafting: responses are published on the FSB website unless the respondent expressly requests otherwise. Cost and template data from a reporting function can be commercially sensitive, so the publication choice is a decision for whoever signs off the response.

The companion G20 Implementation Monitoring Review report supplies the backdrop. It finds that national circumstances, including legal frameworks, market structure and political capacity, are the main reason implementation of agreed policies has been uneven, and that some implementation difficulties can be traced to the FSB’s own policy development process. It follows the 2025 review’s finding of what the FSB called a worrisome slowdown in implementation.

Who the principles address, and the deregulation misreading

The principles are addressed to financial authorities in FSB member jurisdictions, and a footnote extends “financial authorities” to EU institutions that are FSB members. The FSB brings together national authorities from 24 countries and jurisdictions alongside international financial institutions, sector-specific groupings of regulators and supervisors, and committees of central bank experts. The report responds to a request from the US G20 Presidency and draws on a stocktake in which 24 jurisdictions and three standard-setting bodies reported 126 modernisation efforts.

The report has three layers, and they carry different weight. The principles and their preamble in section 1 are the operative text. The additional comments in section 2 explain the preamble and four of the principles (2, 3, 6 and 7), and the report states that they are not part of the principles. The case studies in Annex I are illustrative, and FSB members are not expected to replicate them. A response that disputes a case study is disputing an example; a response aimed at the wording of a principle is aimed at what authorities would commit to.

Reading the exercise as deregulation does not survive the preamble. All eight principles sit under four shared understandings: financial stability is the foundation for sustainable growth, which in turn supports stability; the principles build on the commitment to implement internationally agreed standards; implementation must be consistent with each jurisdiction’s legal framework and circumstances; and the principles aim to preserve or enhance existing levels of financial system resilience. The additional comments add that the principles “do not presume a specific outcome or call for greater or lesser stringency”. One jurisdiction may emphasise sustainable growth; another may recalibrate the intensity of its frameworks to preserve or enhance stability.

The FSB is alert to the misreading. Some stocktake respondents flagged the risk that modernisation efforts could be misunderstood by the public and regulated entities as a race to the bottom, and consultation question 7 asks how communication can avoid that misperception. Principle 1 also cuts both ways. It asks authorities to assess whether frameworks have achieved their intended outcomes or could be enhanced by recalibration, strengthening or elimination.

The eight proposed principles at a glance

The middle column condenses the section 1 text. The right-hand column marks where each principle would touch a reporting function; it is interpretation and carries no FSB authority.

A drafting detail matters for anyone quoting Principle 8 back to an authority. Its title shifts across the document. The executive summary calls for “efficient and effective information reporting and disclosure”, section 1 heads it “Efficiency and effectiveness of regulatory reporting and disclosure”, and the Annex I heading inserts the word “data”. Section 1 is the operative text, so its wording is the one to cite. Principle 3 carries a boundary of its own: its additional comments state that the principle does not set out which risks are material, a question left for authorities to answer themselves.

Principle 8 puts reporting and disclosure under one test

Principle 8 has two sentences with different subjects and different force. The first concerns the requirements themselves: reporting and disclosure requirements for financial institutions “should be efficient, be necessary and proportionate, support effective regulation and supervision, and be reviewed as necessary”. The second concerns how authorities deal with each other: financial authorities in the same jurisdiction “should make best efforts to coordinate the collection and sharing of information with one another, including to minimise duplicative information collection”.

Bundling reporting with disclosure reflects a dependency firms have already run into. When the PRA confirmed the deletion of 37 banking reporting templates in PS27/25 on 8 December 2025, respondents pointed out that certain FINREP templates removed from regular reporting are also referenced in Pillar 3 disclosure requirements, leaving firms with continued obligations to prepare disclosures based on templates that no longer exist as returns. A test applied to reporting alone would miss that link. Our UK FINREP reporting guide covers the template set that remained after those deletions.

The second sentence is narrower than it first reads. “Best efforts” is a soft standard, and “in the same jurisdiction” leaves cross-border duplication outside its text.

PS27/25 shows the gap on a live file. A respondent asked for transitional relief because UK firms with EU subsidiaries may still have to report the deleted templates under EU law. The PRA answered that it is for overseas authorities to determine reporting requirements in their own jurisdictions, and that banks expecting operational complexity should engage with their supervisors on a transitional approach. In my reading, Principle 8 as drafted would leave that answer unchanged. The closest the report comes to the cross-border case is in the stocktake, where respondents suggested the FSB strengthen coordination and monitoring across jurisdictions to watch for divergences that could yield fragmentation.

What the reporting case studies in Annex I show

Reporting is a small slice of the stocktake by label. Graph 1 in Annex II assigns 6% of the 126 efforts to the data and reporting category, against 22% for supervisory effectiveness and 20% for omnibus efforts. Reporting work also turns up inside broader packages: the annex lists trimming duplicative reports among housekeeping actions and notes that many authorities are building data-sharing platforms and unified reporting templates.

Annex I then lists eight case studies under Principle 8, from China, India, Indonesia, Japan, Korea, South Africa, Spain and the United Kingdom. They point in two directions, and a firm’s exposure depends on which one its authorities take.

Fewer collections

Spain and the UK are the subtraction cases. The Bank of Spain ran a full review of national reporting to remove overlaps and low-value items. The report cites a 34% reduction, with a further 16% targeted, without stating the unit behind those percentages. The Bank of Spain’s own note places the reduction in the national reserved financial-information requirements, a narrower set than all domestic regulatory reporting.

The Bank of Spain’s 29 December 2025 press note, on Circular 1/2025 (published in the BOE that day, amending Circular 4/2017 and Circular 1/2013), says the information requirements in the national reserved statements of Circular 4/2017 fall by a third, and that a new omnibus circular, then in prior public consultation and expected to conclude around mid-2026, would, together with Circular 1/2025, bring the reduction to around 50% of the national reserved information required under Circulars 4/2017 and 2/2016. The changes to reserved statements apply for the first time to 31 March 2026 data for monthly and quarterly statements, with later first dates for semi-annual and annual ones. The Bank of Spain also tightened internal governance so that ad hoc requests must be fully justified and necessary. The UK entry describes the PRA’s Future Banking Data programme, whose first deliverable, PS27/25, deleted 34 FINREP templates, two COREP templates and PRA109, taking effect on 31 December 2025 and applying to reporting reference dates falling on that day.

Shared channels and more granular data

The other six entries change the plumbing. China is building a cross-sector data-sharing mechanism between financial regulators and macro authorities to reduce multiple reporting by firms. India’s securities regulator, SEBI, uses a single filing system that shares listed issuers’ submissions across exchanges. Indonesia’s Financial Reporting Single Window (Platform Bersama Pelaporan Keuangan) routes financial statements through one channel that authorised authorities access under their own mandates. Korea gives supervisory authorities common validated datasets from OTC derivatives trade repository reporting, and South Africa’s Prudential Authority and Financial Sector Conduct Authority consolidate submissions on integrated platforms.

Japan’s entry contains the detail that cuts against the easy reading of the whole exercise. The FSA and the Bank of Japan are integrating supervisory data collection through a Common Data Platform that unifies submission channels, and they have unified channels for templates both authorities use. Under the same initiative, they are collecting transaction-level loan data to enhance monitoring. Modernisation in that case adds a granular collection while consolidating channels. Whether a reporting team’s total effort falls depends on how much existing aggregate reporting the granular data replaces, and the case study does not quantify that.

Proportionality, thresholds and the cliff-effect question

Principle 2 asks authorities to consider varying frameworks according to the nature, size, complexity, risk profile, business model and systemic importance of a financial institution. The additional comments name the considerations on the other side, among them effects on a level playing field, regulatory arbitrage and resource implications, and leave the weighing to each authority’s discretion.

The case studies show what proportionality looks like once it reaches a return. Switzerland’s small banks regime allows eligible category 4 and 5 banks and account-holding securities firms to apply for relief. They must meet a simplified leverage ratio of at least 8%, a 12-month average liquidity coverage ratio of at least 110% and a refinancing rate of at least 100%, at both single-entity and financial-group level, and FINMA can reject an application on certain supervisory grounds. They no longer need to calculate risk-weighted assets or the Net Stable Funding Ratio, and they benefit from reduced or simplified reporting and disclosure requirements.

A separate Principle 7 case study records that the regime was piloted with 68 institutions before it was enacted. Our analysis of where the FINMA small banks regime’s proportionality stops covers the obligations that stay in place regardless of size.

In the UK, the PRA’s Strong and Simple framework set out simpler prudential requirements for Small Domestic Deposit Takers (SDDTs). The PRA’s DP1/26 records that the initiative has already simplified liquidity returns for SDDTs and will deliver simplifications to their capital reporting from 1 January 2027. In the United States, the optional community bank leverage ratio framework allows qualifying banking organisations with less than $10 billion in total consolidated assets and a Tier 1 leverage ratio greater than 8%, subject to other eligibility criteria, to opt into the framework, under which a qualifying bank is considered to meet the generally applicable risk-based and leverage capital requirements. The threshold was reduced from greater than 9% with effect from 1 July 2026 (OCC Bulletin 2026-34).

Each of these regimes draws a line, and a line creates a cliff. Question 13 asks how cliff effects for proportionality and tailoring could be appropriately managed, and question 12 asks how authorities can balance tailoring against frameworks that are well understood and easy to implement and administer. The symposium summary records the tension without resolving it: simple frameworks that preserve resilience may require less proportionality, and proportional frameworks that preserve resilience may require complexity.

For a reporting function the cliff has a specific shape. Where eligibility for a simplified regime rests on conditions such as a leverage ratio floor or liquidity tests, a firm near the boundary needs to be able to produce the fuller reporting set if it crosses back, and the switching cost in data sourcing, validation and parallel runs is the kind of evidence question 13 invites. That is my reading of the question. The report itself does not describe exit mechanics for any of the regimes it cites.

Impact analysis is where reporting cost evidence enters

Principle 7 asks authorities to communicate and consult with a broad range of stakeholders in a timely and strategic way on the rationale for proposed policies, to consider the expected costs, benefits and other impacts of significant regulatory and supervisory changes, and to consider the cumulative impact of policies across frameworks instead of judging one policy in isolation. The additional comments go further on disclosure: authorities should consider, and may benefit from, being transparent about assumptions, data limitations, qualitative factors and hard-to-quantify effects.

The UK entries show the machinery from both sides. The Financial Services and Markets Act 2023 established independent Cost Benefit Analysis Panels for the PRA and the FCA, which provide external challenge on cost-benefit work for proposed rules.

PS27/25 shows what happens when firm evidence meets an authority’s estimate. Respondents questioned the projected savings from the template deletions, citing fixed system costs, transition work and the possibility that underlying data requirements for other returns would remain unchanged. The PRA kept its estimates. It explained that its firm-level figures were averages across the reporting population, so firms reporting more of the deleted templates would benefit more than those reporting fewer, and said it would explore whether it could refine some of its cost-benefit inputs on data collection following a forthcoming Future Banking Data discussion paper.

That exchange carries a narrow lesson for a response to the FSB. Cost evidence that separates fixed platform costs from the marginal cost of each template answers the objection the PRA had to weigh, and evidence that shows the same underlying data being cut several ways for different returns speaks to the cumulative-impact limb of Principle 7. Question 14 asks how authorities can best use impact analysis and disclose the assumptions and limitations behind it. The symposium summary adds that some participants cautioned against a false sense of precision and treated ex-post evaluation as essential to check whether reforms deliver their intended outcomes.

Supervisory process changes that reach the reporting desk

Principle 4 is addressed to supervisory authorities and has four limbs: articulate expectations and explain decisions with clarity, transparency and predictability; identify and act on material risks in a timely manner; adopt technology responsibly, with appropriate governance and human oversight, so that it supports supervisory judgement without replacing it; and simplify supervisory processes to reduce unnecessary costs and accelerate routine decisions.

The EU case study comes from ECB Banking Supervision, which is reforming its Supervisory Review and Evaluation Process (SREP) with a multi-year risk-tolerance framework, tiered remediation (self-certification for low-severity issues and intensified measures for high-severity ones), decisions communicated earlier and a simplified Pillar 2 methodology, supported by digitalisation and SupTech. The Bank of Spain uses a multi-year SREP for less significant institutions and has digitalised authorisation and supervisory workflows, for example through direct upload portals. Singapore’s entry describes digital data collection platforms that improve data quality and reduce reporting frictions.

Tiered remediation has a documentation consequence. Where a low-severity finding is closed by self-certification, the bank’s own record of the fix becomes the evidence the supervisor relies on, so that record carries more weight than under a full supervisory follow-up. That is my inference from the case study; the FSB text does not describe how self-certification is evidenced. Our report on the ECB’s planned supervisory reporting cuts covers the data side of the same ECB agenda.

Mapping the 14 consultation questions to reporting evidence

The FSB invites comments on all aspects of the report and encourages detailed responses with supporting information. Responses go through the secure online form; questions and supplemental material go to the FSB by email at fsb@fsb.org. Six of the 14 questions line up with evidence a reporting function holds. The right-hand column below is a suggestion and has no FSB standing.

Two constraints shape what goes in. The principles address authorities, so evidence carries most weight when it describes the effect of an authority’s choice: a duplicate collection, an unaligned definition, an ad hoc request that sits outside the regular framework. And because the principles leave implementation to each jurisdiction, evidence tied to a named domestic collection gives an authority something specific to act on.

Where modernisation would reach your returns

Change to returns would arrive through the domestic programmes the FSB modernisation principles are meant to guide, and several were running before the consultation opened.

In the UK, the PRA’s DP1/26 of 4 February 2026 proposes four principles for Future Banking Data that track Principle 8 closely: anchoring the data collected in the PRA’s objectives, collecting data “once and well” by minimising what is collected while maximising its use, making it easier for firms to supply data, and keeping collected data fit for purpose over time. The paper lists trade-offs the PRA would weigh, including granular versus aggregated formats and the balance between regular reporting and one-off requests, and says the PRA will work with firms to develop a roadmap for pragmatic and incremental reforms in light of responses.

In the EU, the EBA’s 10 April 2026 consultation on its supervisory reporting simplification package proposed a 16% reduction in data points in regular EU harmonised ITS supervisory reporting, around 55% fewer data points in EU-wide stress-test collections (against the last exercise) and up to 65% fewer in supervisory benchmarking. The EBA’s executive summary puts the overall net reduction, combining regular reporting and EU-wide stress-test collections, at around 50%, even after additional requirements such as IFRS 18, ESG and FRTB. The package also proposed integrating the separate EU-wide stress test and supervisory benchmarking data collections into regular reporting, and the EBA said it will develop an EU-wide public repository of European and national supervisory data requests. The April consultation envisaged implementation of the wider simplification changes from September 2027.

Separately, on 12 October 2026 the EBA released the final technical package for reporting framework 4.4 Phase 1, covering an IFRS 18-aligned FINREP module and Pillar 3 disclosure changes, and stated that the Phase 2 technical package for the simplification changes is expected in early 2027. The EBA’s framework 4.4 schedule lists March 2027 as the expected first reference date for IFRS 18 in FINREP and September 2027 as the expected first reference date for the remaining Phase 2 simplification elements. The 12 October release says the new FINREP module is to be used together with the EBA’s 8 July 2026 Opinion on the implementation of IFRS 18 in supervisory financial reporting, which advises competent authorities to let institutions use IFRS 18-aligned FINREP templates voluntarily in the interim. The same Opinion says mandatory application of the amended FINREP ITS incorporating IFRS 18 is currently expected from the end of September 2027, so a March 2027 reference date falls within that interim period.

The EU-wide repository of supervisory data requests that the EBA has said it will develop looks like the nearest EU counterpart to Principle 8’s coordination sentence. On the markets side, ESMA’s July 2026 final report on transaction reporting recommends long-term integration of MiFIR, EMIR and SFTR so that firms report once. Our coverage of the EBA supervisory reporting simplification consultation and of ESMA’s transaction reporting simplification plan follows both files.

Frequently Asked Questions

Our home authority is not an FSB member. Do the principles matter for us?

Possibly. The additional comments on the preamble state that the principles are written for authorities in FSB member jurisdictions but may nevertheless be relevant to financial authorities in other jurisdictions. The FSB also conducts outreach with around 70 other jurisdictions through six Regional Consultative Groups. Nothing in the report commits a non-member authority to implement anything.

If an authority’s reading of a section 2 comment conflicts with the principle itself, which prevails?

The principle. A footnote to section 2 states that where the additional comments conflict with the proposed principles, the proposed principles take precedence. The rule applies to the comments on the preamble as well as those on Principles 2, 3, 6 and 7.

Can a firm cite Principle 8 to decline a data request it considers duplicative?

It cannot serve as a legal ground. The statement in the report says FSB activities and decisions give rise to no legal rights or obligations, and Principle 8’s coordination sentence is a best-efforts standard addressed to authorities. A request continues to rest on the requesting authority’s own legal basis. Once a final version exists and an authority has committed to it, the principle can frame a conversation about overlap with that authority; it gives the firm no ground to refuse.

Does “financial authorities in the same jurisdiction” cover EU-level bodies and national supervisors collecting from the same bank?

The report does not say. Footnote 1 includes EU institutions that are FSB members within “financial authorities”, but neither Principle 6 nor Principle 8 explains how “the same jurisdiction” applies when an EU body and a national authority both collect from one institution. Treating that overlap as covered would go beyond the text, and question 10, on whether the preamble sets sufficient parameters, is the place to ask.

Will the FSB monitor whether authorities implement the principles?

The consultation report is silent on a monitoring or peer-review exercise for the principles. Its executive summary records that FSB members will continue to share good practices and observations about their frameworks, including their modernisation efforts, with one another to support learning and well-aligned efforts. Respondents who want a formal monitoring mechanism can say so in the consultation.

Are insurers, asset managers and payment firms in scope, or is this a banking exercise?

The principles address financial authorities without limiting themselves to one sector, and the stocktake reflects that breadth. Banks and credit institutions were in scope of 81 of the 126 reported efforts, insurers and reinsurers 49, asset managers and investment funds 46, financial market infrastructures 45, market intermediaries 45 and payments and e-money providers 33. Fintech firms, crypto-asset service providers and pension funds appear most often in the “other” category, which covered 56 efforts.

Related Articles

• UK FINREP Reporting: PRA Rules, Templates and Filing Deadlines: the UK FINREP framework under the PRA Rulebook, including the templates removed by PS27/25.
• FINMA Small Banks Regime: Where Proportionality Stops: what Switzerland’s voluntary small banks regime simplifies and which obligations remain for every bank.
• EBA Supervisory Reporting Simplification: What to Flag: the EBA’s April 2026 consultation on simplifying EU supervisory reporting and the points banks should check.
• ECB Supervisory Reporting: The Cuts Buch Confirmed at Bruegel: the ECB’s plans to trim bank-specific data requests and stress-test data, as set out in September 2026.
• Transaction Reporting Simplification: ESMA’s EUR 1bn Plan: ESMA’s July 2026 recommendations for integrating EMIR, MiFIR and SFTR reporting.
• FSB AI Sound Practices Final Report: A Governance Gap Analysis: the FSB’s October 2026 final report on twelve non-binding AI sound practices.

Key Takeaways

• Quote Principle 8 from section 1 of the report; the executive summary and Annex I headings use different wording.
• Plan UK/EU dual reporting on each authority’s own rules: Principle 8’s coordination sentence reaches only authorities in the same jurisdiction, on a best-efforts basis.
• Split any cost evidence into fixed platform costs and per-template costs before it goes to an authority.
• Inventory returns by collecting authority: overlaps between authorities in one jurisdiction are what Principle 8’s second sentence addresses.
• Track the domestic files for actual change: the PRA’s Future Banking Data roadmap, the EBA simplification package and ESMA’s report-once recommendation.
• Expect the final FSB report in the first half of 2027, with implementation left to each authority’s legal framework and no FSB timetable.

Sources and References

• Financial Stability Board, press release “FSB consults on high-level principles for regulatory and supervisory modernisation” (14 October 2026, ref. 13/2026): fsb.org
• Financial Stability Board, Regulatory and Supervisory Modernisation Principles: Consultation report (14 October 2026), publication page: fsb.org
• Financial Stability Board, Regulatory and Supervisory Modernisation Principles: Consultation report (PDF): fsb.org/uploads/P141026-1.pdf
• Financial Stability Board, G20 Implementation Monitoring Review: 2026 report (14 October 2026): fsb.org
• Bank of England, Prudential Regulation Authority, PS27/25 Future banking data review: Deletion of banking reporting templates (8 December 2025): bankofengland.co.uk
• Bank of England, Prudential Regulation Authority, DP1/26 Future banking data (4 February 2026): bankofengland.co.uk
• European Banking Authority, press release “The EBA consults on major simplification of supervisory reporting to deliver a simpler, smarter and more proportionate framework” (10 April 2026): eba.europa.eu
• European Securities and Markets Authority, ESMA’s contribution to simplification and burden reduction, ESMA22-1669215091-6873 (28 September 2026), section 3.1 on transaction reporting: esma.europa.eu
• European Securities and Markets Authority, Final Report on the Call for Evidence on a comprehensive approach for the simplification of financial transaction reporting, ESMA12-1406959660-3235 (July 2026): esma.europa.eu
• European Banking Authority, Efficient reporting: simpler, smarter, proportionate (EBA/REP/2026/07, 10 April 2026), executive summary: eba.europa.eu
• European Banking Authority, reporting framework 4.4 schedule: eba.europa.eu
• European Banking Authority, press release “The EBA releases the final technical package for release 4.4 of its reporting and Pillar 3 disclosure framework” (12 October 2026): eba.europa.eu
• European Banking Authority, press release on the Opinion on the implementation of IFRS 18 in supervisory financial reporting (8 July 2026): eba.europa.eu
• Banco de Espana, press note on Circular 1/2025 (29 December 2025): bde.es
• Boletin Oficial del Estado, Circular 1/2025 of the Banco de Espana (BOE-A-2025-26847): boe.es
• FINMA, Cat. 4 and 5 / Small banks regime, admission criteria: finma.ch
• Office of the Comptroller of the Currency, Bulletin 2026-34, community bank leverage ratio: occ.gov

The evidence pack worth sending to the FSB

The artifact to produce before the form closes on Friday 8 January 2027 is a short evidence pack keyed to the question numbers in the mapping table above, with each figure tied to a named collection and authority. The decisions to take first are whether it goes in under the firm’s own name or through an industry association, and which of its figures the firm is prepared to see published on the FSB website.

Disclaimer: The information on RegReportingDesk.com is for educational and informational purposes only. It does not constitute legal, regulatory, tax, or compliance advice. Always consult your compliance officer, legal counsel, or the relevant supervisory authority for guidance specific to your institution.