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    Banking and Finance Law Daily Wrap Up, CAPITAL AND BASEL ACCORDS—Basel Committee addresses machine-readable disclosures by banks, (Dec 9, 2025)

    By Charles A. Menke, J.D.

    The Committee is proposing additions to its disclosure standard to make the data disclosed by banks—so-called Pillar 3 disclosures—available in a machine-readable format.

    The Basel Committee on Banking Supervision has published a consult ...

    By Charles A. Menke, J.D.

    The Committee is proposing additions to its disclosure standard to make the data disclosed by banks—so-called Pillar 3 disclosures—available in a machine-readable format.

    The Basel Committee on Banking Supervision has published a consultative document and accompanying abstract proposing additions to the current disclosure standard in its Pillar 3 disclosure framework for a standard format for machine-readable disclosures by banks. According to the document, the proposed standard format would make existing disclosure by banks more accessible and easier to aggregate. The Committee requested comments on the proposals by Mar. (5, 2026)).

    “Banks’ Pillar 3 disclosures reduce information asymmetry and help promote comparability of banks’ risk profiles within and across jurisdictions,” the document noted. “The disclosure requirements enable market participants to access key information relating to a bank’s regulatory capital, liquidity parameters and other risk exposures, which in turn helps increase transparency about a bank’s affairs and reinforces market participants’ confidence therein.” The “availability of Pillar 3 disclosures in machine-readable standardised formats is important for strengthening market discipline and efficiency,” the document states, since it “enhances the speed and ease of data processing [and] also provides scalability and flexibility to data users.”

    The Committee “believes that the usefulness of Pillar 3 disclosures would be improved by a requirement across all BCBS member jurisdictions that they be provided in a machine-readable format either by banks directly and/or via a central repository at the national or regional level that is approved by the supervisor for all banks in a jurisdiction.” The Committee added that “[m]aking disclosure data more easily accessible would provide a valuable public good.”

    The proposed standard would add a requirement and technical specifications for banks to produce machine-readable quantitative Pillar 3 disclosures. Although, the material disclosure requirements for banks would not be changed, the proposal would require additional technical templates for providing metadata such the bank’s identity, the reporting currency and unit, and a uniform resource locator (URL). Banks that publish Pillar 3 disclosures on their own websites would be required to provide their supervising regulator with the base URL of the webpage hosting the disclosure data. In those jurisdictions where a regulator elects for Pillar 3 disclosure through a centralized repository, the proposed changes and additions to the standard would apply to the centralized repository rather than to the banks’ own websites.

    The Committee does not believe the proposal would increase the burden on banks in those jurisdictions where machine-readable Pillar 3 disclosures are already required. Instead, existing procedures could be incorporated into the proposed global standard.

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