Articles — BCBS 239 and RDARR
Analysis that revisits specific points of BCBS 239 and the ECB's RDARR Guide.
BCBS 239: does it allow exceptions? Trade-offs, materiality and expert judgement
BCBS 239 isn't limited to its 14 principles: the text also sets out cross-cutting requirements — controlled trade-offs, justified materiality, documented expert judgement — that apply across the whole framework.
Are financial reports covered by BCBS 239? The ECB's response to the industry
Why does the RDARR Guide also apply to financial statements, already governed by strict accounting standards and independent external audit? Several banking federations raised the question — without convincing the ECB.
What does an RDARR remediation plan look like? What the ECB expects
The 7th and final area of the RDARR Guide is about neither data nor reporting, but about how a bank must steer its own compliance programme.
Are internal models covered by BCBS 239? From Pillar 1 to Pillar 2
An internal ratings model or a VaR model isn't just an algorithm: it's also a data chain, with its own accuracy and traceability requirements. Here's how BCBS 239 and the RDARR Guide apply to it.
Must all data be traced? What the RDARR Guide really expects of data lineage
The EBF considered end-to-end traceability unrealistic for large banks. The ECB held its ground, while clarifying a pragmatic approach. It's one of the most contested debates of the entire public consultation.
Does the RDARR Guide replace BCBS 239? What the ECB says
After ten articles on this site devoted to the RDARR Guide, one question deserves to be asked directly: is this 2024 text meant to replace BCBS 239? The ECB answered, in black and white, during the public consultation.
The proportionality principle: how far must an institution really go?
"Proportionate" appears in almost every section of the RDARR Guide, without ever being precisely defined. One institution eventually asked the ECB what the word really means. The answer is more nuanced than a single number.
Can a merger break your data architecture? What BCBS 239 says
A merger or acquisition suddenly brings together two systems, two taxonomies, two sets of customer identifiers. BCBS 239 has anticipated this since 2013 — and the ECB's RDARR Guide clarifies its governance.
Are spreadsheets doomed by RDARR? What the Guide really says
The common assumption is that banking supervisors want to eradicate spreadsheets and EUC applications. The RDARR Guide's public consultation tells a more nuanced story — and a more reassuring one for those who use them correctly.
Who does what? Data owner, data producer and delegation by the management body
Among the 308 comments received by the ECB, the question of "who is responsible for what" comes up constantly. Two points in particular mobilised the industry: the definition of the data owner, and the management body's room to delegate.
Data quality: what the Basel Committee and the ECB expect
"Ensuring data quality" often remains a vague phrase. BCBS 239 and the ECB's RDARR Guide, however, describe very concrete mechanisms: a single source per risk type, a data dictionary, an issues log, and spreadsheet controls.