Placing BCBS 239 and the RDARR Guide in context

Timeline — from the 2007-2008 crisis to the 2024 Guide

The story of BCBS 239 unfolds across two threads that eventually converge: the Basel Committee's international standard, designed after the crisis and then implemented through to the 2016 deadline, and European banking supervision by the ECB, which made it a priority focus of its work from its 2016 thematic review through to the RDARR Guide of May 2024.

Basel thread — international standard ECB thread — European supervision Each date is sourced to its corresponding official text.
Basel
International standard
The global framework, developed after the financial crisis
  1. 2007-2008
    The crisis reveals aggregation weaknesses

    Banks' shortcomings in risk data aggregation and reporting practices contribute to the crisis's severe difficulties: supervisors and management struggle to obtain a reliable, aggregated view of risk.

    Ref. BCBS 239, introduction
  2. 4 November 2011
    The FSB calls for a framework

    The Financial Stability Board's (FSB) progress report on enhanced supervision recommends developing supervisory expectations for systemically important financial institutions (SIFIs) and sets the G-SIB deadline for early 2016.

    Ref. BCBS 239, introduction · FSB, 4 Nov. 2011
  3. Nov. 2011 / Nov. 2012
    G-SIBs are identified

    The FSB publishes its annual lists (4 November 2011, then 1 November 2012). G-SIBs designated on these two dates must comply with the principles by January 2016; those designated in subsequent annual updates have three years.

    Ref. BCBS 239, "Scope and initial considerations"
  4. January 2013
    BCBS 239 is published

    The Basel Committee publishes the Principles for effective risk data aggregation and risk reporting: 14 principles organised into four sections (governance and infrastructure, aggregation capabilities, reporting, supervisory review).

    Ref. BCBS 239
  5. Early 2013
    Supervisor/G-SIB dialogue and self-assessments

    National supervisors begin discussing implementation with G-SIBs' senior management and are likely to require self-assessments, with the aim of closing significant gaps before 2016.

    Ref. BCBS 239, section V
  6. 2013 — annual monitoring
    The Basel Committee tracks progress

    The Committee tracks implementation through its Standards Implementation Group (SIG) from 2013, and shares its findings with the FSB at least once a year from the end of 2013.

    Ref. BCBS 239, section V
  7. January 2016
    G-SIB compliance deadline

    G-SIBs designated in November 2011 or 2012 must be compliant. The Committee acknowledges some flexibility in exceptional circumstances (for example, for outsourced processes). Supervisors are encouraged to apply the principles to domestic systemically important banks (D-SIBs), three years after their designation.

    Ref. BCBS 239, section V and "Scope and initial considerations"
ECB
European supervision
Monitoring and strengthening the framework in the euro area
  1. 2016
    The RDARR thematic review

    The ECB assesses 25 significant institutions against the BCBS 239 principles, supplemented by a "data lineage" exercise (credit risk) and a "fire drill" exercise (liquidity risk). Finding: no institution, including among the G-SIBs, fully follows the principles.

    Ref. RDARR Guide, section 1
  2. May 2018
    The thematic review report

    The ECB's thematic review report identifies good practices and areas of concern; it serves as a reference for assessing institutions' RDARR capabilities, in application of the BCBS 239 principles.

    Ref. RDARR Guide, sections 1-2 · consultation feedback statement
  3. 14 June 2019
    ECB letter to significant institutions

    The ECB sends a letter to all significant institutions in the SSM, demanding substantial and rapid improvements and the implementation of integrated reporting solutions considered good practice.

    Ref. RDARR Guide, section 1 · consultation feedback statement · ECB letter, 14 June 2019
  4. 24 July 2023
    Public consultation launched

    The ECB opens an 11-week public consultation on the draft Guide and informs the European Parliament.

    Ref. consultation feedback statement
  5. 15 September 2023
    Stakeholder meeting

    More than 300 online participants engage with the ECB on the questions and uncertainties raised by the draft Guide.

    Ref. consultation feedback statement
  6. 6 October 2023
    Closes: 308 comments

    The consultation gathers 308 comments, covering the seven sections of Chapter 3 of the Guide. The feedback statement groups them into 186 blocks, with the ECB's response and an indication of amendments.

    Ref. consultation feedback statement
  7. 2023-2025
    A priority work programme

    The Guide is a key element of the 2023-25 work programme: targeted engagement on priorities, horizontal benchmarking of findings, and more intrusive use of supervisory powers (SREP, on-site inspections, remedial measures). In the 2023 SREP cycle, RDARR ranked as the worst-rated internal governance sub-category.

    Ref. RDARR Guide, section 4 · 2023 SREP cycle
May 2024 — the two threads converge
The RDARR Guide and the feedback statement

The ECB publishes the Guide on effective risk data aggregation and risk reporting: seven minimum supervisory expectations (management body responsibilities, scope of application, data governance, integrated architecture, group-wide data quality, timeliness of reporting, implementation programmes). It does not replace the BCBS 239 principles: it clarifies their implementation, pursuant to European legal requirements. A feedback statement details the ECB's responses to the 308 comments.

The RDARR Guide in detail → The 2023 consultation and its 308 comments → Does the Guide replace BCBS 239? →

→ The 14 BCBS 239 principles → ECB's RDARR Guide → Compliance self-assessment