EDW Responds to FCA Consultation on Reforming the UK Securitisation Framework

The UK Financial Conduct Authority (FCA) launched Consultation Paper CP26/6, Rules for reforming the UK Securitisation Framework, on 17 Feb 2026. The consultation forms part of the UK’s broader review of the securitisation regime and seeks to simplify disclosure requirements, reduce unnecessary operational burden, and improve the usability of securitisation reporting for market participants and supervisors. Stakeholders were invited to submit responses by 18 May 2026.

European DataWarehouse (EDW) supports the FCA’s intention to simplify the UK securitisation transparency framework and improve the usability of disclosure. However, it considers that several proposals in the consultation risk undermining core features of the post global financial crisis regulatory framework, in particular transparency, comparability, and effective supervisory oversight.
A central concern is that the consultation does not fully reflect the role and operational experience of regulated Securitisation Repositories (SRs). In particular, EDW notes that SRs were not represented in key industry roundtables, creating a risk that issues relating to data access, usability, and costs have been misattributed to SRs, rather than to underlying regulatory design choices (such as mandatory XML) or reporting practices by manufacturers.

Taken together, these proposals risk weakening the effectiveness of the UK transparency regime and creating unintended consequences for market participants, investors, and supervisors:

• Fragmenting disclosure across unregulated channels, weakening comparability and increasing investor costs;
• Disrupting supervisory data continuity in the absence of a clear replacement framework; and
• Underestimating transition and duplication costs while overstating likely savings.

EDW therefore advocates a targeted reform approach, retaining securitisation repositories as the central disclosure infrastructure while addressing specific drivers of cost and complexity. Most notably, XML requirements, overly prescriptive operational rules, and a limited set of problematic data fields.

EDW supports the FCA’s proposal to remove the requirement for XML reporting, recognising that XML has proven operationally complex and difficult for many users to integrate into standard analytical workflows.
However, removing XML should not mean abandoning structured and standardised reporting. EDW therefore recommends replacing it with a clear requirement for structured, tabular, standardised formats, ensuring both flexibility and continued comparability.

The FCA proposal for a purely principles based requirement for data to be “electronic and machine readable” is insufficient. Without further clarification, this could permit formats such as PDFs that technically meet the requirement but do not preserve data structure or support meaningful automated analysis.

Structured, tabular formats (e.g. CSV or Excel) are essential to ensure that:

• Data can be easily analysed, compared, and aggregated;
• Investors can perform cross-transaction and cross-originator analysis efficiently; and
• Data integrity is preserved through consistent formatting.

Removing standardisation would shift the burden of data normalisation and interpretation onto investors, increase inconsistency between issuers, and undermine the FCA’s objective of improving usability.

A fundamental issue with CP26/6 is that it risks misdiagnosing the source of current challenges. The Consultation incorrectly attributes issues around data access, usability, and operation costs to SRs, when in practice they arise from the regulatory framework requirements.

In particular, mandatory XML reporting, the query-based access model, and other prescriptive operational requirements constrain how SRs can present, extract, and deliver data to users.

As a result, shortcomings that are in fact consequences of regulatory design risk being treated as evidence of SR underperformance.

EDW therefore recommends a less prescriptive regulatory framework that would allow SRs greater operational flexibility to improve usability while preserving the benefits of a regulated disclosure infrastructure.

EDW supports the simplification of templates but highlights that the proposed approach risks focusing on superficial reductions rather than the true drivers of cost and data quality issues.

EDW’s empirical data quality analysis shows that reporting issues are highly concentrated in a small number of key fields (e.g. arrears metrics, balances, default-related fields, and valuation data). The majority of these fields are retained in the proposed templates. As a result:

• A reduction in the number of fields will not materially reduce the reporting burden;
• Data quality improvements are likely to be limited; and
• Operational complexity will persist.

EDW analysis also highlights that UK data quality outcomes lag behind EU benchmarks, indicating that structural template design is not the primary driver of quality issues.

In addition, partial alignment with Bank of England templates does not eliminate duplication. Firms will still need to:

• Maintain multiple data models
• Perform parallel mapping and validation
• Manage ongoing reporting complexity

EDW recommends that reform efforts focus on targeted remediation of high-impact data fields, supported by empirical evidence. As well as greater convergence across reporting regimes, rather than relying on headline reductions in template size.

EDW raises concerns that the proposed introduction of a revised CLO template would impose material implementation costs and operational complexity, which are not adequately reflected in the FCA’s analysis. The transition to a new template requires:

• System reconfiguration;
• Data mapping and transformation; and
• Alignment of existing datasets with new reporting structures.

Even where the number of fields is reduced, firms must still undertake significant transition work, including bridging differences between current and proposed templates.

EDW also notes that similar challenges would arise across other asset classes, particularly where reporting frameworks become less standardised.

EDW strongly disagrees with the proposal to remove the requirement to report to securitisation repositories, viewing this as the most consequential and high‑risk element of CP26/6 for the following reasons:

Fragmentation of disclosure

SRs currently provide a centralised, standardised access point for securitisation data. Removing this would fragment disclosure across multiple platforms, increasing search costs and reducing comparability.

Increased operational burden and unequal impact across the market

Fragmentation disproportionately disadvantages smaller investors and new entrants and implicitly favours large institutions with extensive internal data infrastructure.

Transfer of operational and regulatory risk

Regulated SRs operate under stringent operational standards which include detailed requirements on governance, continuity, data integrity, operational resilience, and information security.

The practical effect of removing SRs is to transfer repository due diligence and operational risk management from the regulator and regulated SRs to the manufacturers, without reflecting those additional costs in the cost benefit analysis.

EDW considers this neither proportionate, nor consistent with the FCA’s stated objectives.

Reduced ability to detect fraud and irregularities

Loan-level data is an important tool for identifying potential fraud, misrepresentation and operational irregularities in securitisation structures. Granular, standardised information enables supervisors, investors and third-party analytics providers to detect red-flag indicators such as inconsistent balances, implausible arrears patterns, repeated valuation anomalies, abnormal default timing and potential double pledging. Many of these indicators are difficult to identify from aggregate or narrative disclosure alone.

SRs apply extensive validation and proprietary data quality checks across complete loan‑level datasets, supporting cross‑loan and cross‑deal analysis that is critical to early fraud detection and supervisory intervention. A decentralised model would be less capable of replicating this preventative function consistently, increasing the risk that material issues are identified only later, with greater impact on investors and market confidence.

Supervisory data loss

SRs provide regulators with a single structured dataset for market‑wide analysis. Removing them risks reducing supervisory visibility unless an equivalent system is introduced.

Removing SRs would increase costs, weaken transparency, and reduce supervisory effectiveness, contrary to the FCA’s stated objectives.

EDW proposes a targeted reform model that addresses inefficiencies while preserving the core benefits of the current framework:

• Retaining securitisation repositories as the default disclosure channel
• Replacing XML with structured tabular formats (CSV/Excel)
• Introducing a core dataset with asset‑specific extensions, reducing duplication
• Using empirical data to identify and correct high-impact fields driving cost and errors
• Simplifying overly prescriptive operational requirements while maintaining core standards on governance, resilience and data integrity

This approach aligns more closely with the FCA’s objectives of reducing burden and improving usability, without introducing fragmentation or loss of oversight.

A targeted reform approach can deliver meaningful cost reduction and usability improvements while preserving transparency, comparability, and supervisory capability.

EDW assesses that the FCA’s Cost Benefit Analysis (CBA) materially overstates cost savings and understates ongoing and transition costs. EDW argues that removing SRs would not eliminate costs but instead shift them to other providers or internal solutions. In many cases, those replacement costs may be equivalent or higher. The loss of regulated SR pricing frameworks could also reduce transparency and lead to higher and more variable costs, particularly for smaller market participants.

In particular, the CBA rests on assumptions that do not fully reflect how reporting, compliance, and data access costs arise in practice. In particular, the CBA assumptions:

• Attribute large costs to SR reporting that, in practice, reflect broader operational and compliance obligations;
• Do not adequately account for costs that will persist under any framework, including:
  • Data distribution;
  • Compliance with parallel regimes; and
  • Internal systems and controls.

The CBA also does not fully capture:

• Costs of fragmented disclosure
• Duplication of investor effort
• Loss of comparability and standardisation

EDW considers that the CBA underestimates the true economic impact of the proposals and should be revisited to reflect market realities.

Data Quality Issues Are Concentrated, Not Structural

EDW’s data quality analysis demonstrates that reporting issues are highly concentrated in a limited number of key fields, particularly arrears metrics, balances, default-related fields and valuation data. As these fields are largely retained in the proposed templates, reductions in template size alone are unlikely to materially improve data quality or reduce reporting burden.

UK Data Quality Underperforms EU

Further analysis shows that UK data quality outcomes lag behind EU benchmarks, indicating that structural format changes (such as the removal of XML) are not the primary drivers of data quality performance. Instead, issues arise from inconsistent reporting practices and field-level definitions, reinforcing the need for targeted remediation rather than broad structural simplification.

Template Alignment remains Partial (BoE vs FCA)

EDW’s operational evidence also confirms that proposed template changes achieve only partial alignment with Bank of England reporting frameworks, meaning firms will continue to operate within a multi-template environment requiring parallel data models, mapping and validation processes. As a result, operational complexity and associated costs are expected to persist, with additional transition costs arising from template changes.

Regulated SRs Provided Embedded Data Quality Infrastructure

As a regulated securitisation repository, EDW applies an extensive data quality and validation framework as part of its supervisory function. These controls support consistency, comparability and reliability of securitisation disclosure and form part of the embedded market infrastructure. Their removal would shift validation and reconciliation responsibilities to market participants, increasing aggregate cost while reducing overall data quality consistency.

Centralised Access Supports Market Efficiency

In addition, securitisation repositories provide a centralised access point for loan-level data and transaction information, supporting efficient cross-deal analysis, investor due diligence and supervisory oversight. Fragmentation of disclosure across multiple channels would increase search costs, reduce comparability and disproportionately impact smaller market participants.

SRs Provide Market-Wide Oversight

From a supervisory perspective, repositories provide a single structured dataset enabling market-wide analysis and monitoring. Removal of this framework would risk a loss of supervisory data continuity in the absence of a clearly defined replacement mechanism.

Taken together, EDW’s empirical evidence demonstrates that the key challenges identified in the current framework are targeted and addressable, while the underlying infrastructure provided by securitisation repositories remains central to data quality, market efficiency and effective supervision.

EDW supports the FCA’s objective of improving the efficiency and usability of the UK securitisation framework. However, the proposed reforms should preserve the core principles that have underpinned the post-crisis regime: transparency, comparability, and effective supervisory oversight.

EDW’s response argues that targeted reforms, including the removal of XML requirements, simplification of operational rules, and remediation of high-impact data fields, can deliver meaningful benefits without introducing fragmentation or weakening supervisory visibility. Securitisation repositories continue to provide critical market infrastructure that supports data quality, investor due diligence, and regulatory oversight.

Taken together, EDW’s analysis suggests that the challenges identified by the FCA are targeted and addressable, while the benefits of a centralised, regulated disclosure framework remain significant for investors, issuers, and supervisors alike.

Access the full EDW response to the FCA Consultation Paper CP26/6 below.