In a recently published consultation paper1, the ECB challenges the banking in-dustry in the context of risk data aggregation and risk reporting (RDARR). On top of much-needed clarity on expectations for RDARR implementation, it first and foremost proposes a wide scope of applicability and exerts regulatory pressure on implementation projects. ECB demands that RDARR be treated as a key priority and raises the prospect of capital add-ons in case of material breaches.

Based on the effort of the industry so far, we expect this paper to be a major uptick for most affected banks in terms of priority and resources dedicated to data ma-nagement programs.