Does the RDARR Guide replace BCBS 239? What the ECB says

Eleven years separate BCBS 239 from the ECB's RDARR Guide. A text this detailed, published so long afterward, might suggest it rewrites, or even replaces, the Basel Committee's 14 principles. The question was put directly during the public consultation — and the ECB's answer is unambiguous.

The Guide itself says so, in black and white, right from its introduction: it does not impose new requirements, and the topics it addresses are not intended to be exhaustive, nor to limit any future supervisory follow-up on RDARR capabilities. The ECB specifies that it expects institutions to read this Guide in conjunction with the BCBS 239 principles — not in their place. (ECB Guide, introduction)

"Will the Guide lead to changes in BCBS 239?" — the question asked head-on

The EBF asked whether an update to the original BCBS 239 text should be anticipated as a result of the Guide. The ECB's answer is categorical: the Guide is not intended to replace or update the existing BCBS 239 principles. On the contrary, it aims to complement them, and to identify important aspects of their implementation from a banking supervision perspective. (ECB consultation feedback statement, May 2024 — Table 1, comment 12)

A deliberately different structure

The EBF also pointed to a lack of clarity in the structure the Guide follows for RDARR governance, compared with that of BCBS 239 — a risk, in its view, of divergent interpretations of the scope of application. The ECB's response owns this choice: it intentionally uses a structure different from that of the BCBS 239 principles, considered better suited to a targeted dialogue between supervisors and institutions. The ECB specifies that the Guide does not cover the entirety of RDARR-related topics — but that, in substance and in its use of terminology, it aims to remain consistent with the BCBS 239 principles. (ECB consultation feedback statement, May 2024 — Table 1, comment 14 — amendment made)

Why only some points, and not a complete rewrite?

Two further EBF comments shed light on this choice of a partial scope. On roles: one respondent was concerned that the roles defined by BCBS 239 (for example, for senior management or data users) were not fully carried over into the Guide. The ECB answers that the draft Guide's ambition is not to provide a detailed blueprint or the full set of data governance elements, but to focus on the most severe deficiencies observed during on-site inspections and ongoing supervision — institutions being expected to read this Guide alongside the BCBS 239 principles, not in their place. (ECB consultation feedback statement, May 2024 — Table 1, comment 15 — amendment made)

On reporting: another respondent was surprised that the Guide only addresses the timeliness of reporting, without covering the other Pillar III qualities of BCBS 239 (accuracy, clarity, comprehensiveness, distribution). The ECB's answer is direct: timeliness was chosen precisely because it is among the deficiencies most frequently observed during on-site inspections and ongoing supervision. The Guide is therefore not a principle-by-principle re-synthesis of BCBS 239 — it is a document built around the points where the ECB empirically finds that banks most often fall short. (ECB consultation feedback statement, May 2024 — Table 1, comment 16 — amendment made)

The Guide also does not provide "best practices"

A comment from the ESBG asked for more detail on the best practices to follow, to enable more effective implementation of remediation programmes. The ECB draws a clear distinction here: the Guide is not intended to provide best practices — these were the main subject of the 2018 thematic review report, and are covered by several Basel Committee progress reports. The Guide, for its part, explains how the applicable framework defines, in the ECB's view, a minimum for effective RDARR. Best practices and other aspects of RDARR remain available in the multiple publications already referenced and in industry standards. Supervisors seek to complement — but cannot substitute for — collaboration and knowledge-sharing within the industry. (ECB consultation feedback statement, May 2024 — Table 2, comment 3)

And on the international stage?

Given BCBS 239's global reach, the EBF asked how other regulatory authorities around the world were involved in the process. The ECB states that it is in active dialogue with international supervisory authorities, within the framework of the Basel Committee and other bodies, complemented by bilateral or ad hoc exchanges — and that the Basel Committee's recently published progress report notes consistent observations and converging supervisory expectations at international level. (ECB consultation feedback statement, May 2024 — Table 1, comment 13)

Why 2024, when BCBS 239 dates from 2013?

The question of "why now" is answered elsewhere on this site, in the full timeline running from the 2007-2008 crisis to the 2016 thematic review, the 2018 report and the 2019 letter (see the dedicated article). But the short answer, consistent with everything above, is this: the ECB did not need a new set of principles after finding, in 2018, that no significant institution — not even the most systemic ones — fully followed BCBS 239. It needed an operational document, targeted at the root causes of this persistent shortfall (project management and the role of the management body, in its own words), and at the deficiencies most frequently found on the ground. That is precisely what the RDARR Guide is — no more, no less.

Key takeaway

BCBS 239 and the RDARR Guide are not two competing versions of the same text, but two documents with different functions. BCBS 239 remains the reference text, whose stated objectives back in 2013 remain broad: enhancing the reporting infrastructure used by the board and senior management, making decision-making more reliable across the banking organisation, and reducing the probability and severity of losses arising from risk management weaknesses (BCBS 239, "Objectives" section). The RDARR Guide is the ECB's operational translation of part of these objectives — deliberately partial, focused on the points where, more than ten years into implementation, shortcomings remain most frequent. Reading one without the other means missing half the picture.

This article is based on three documents: the Basel Committee's 14 BCBS 239 principles (January 2013), the ECB's RDARR Guide (May 2024), and the ECB's feedback statement on the RDARR Guide's public consultation (May 2024).