On March 3, ISDA, the Institute of International Finance (IIF) and the Global Financial Markets Association (GFMA) submitted a joint response to the Basel Committee on Banking Supervision consultation on machine-readable Pillar 3 disclosure.

The associations support the Basel Committee’s objective to enhance Pillar 3 disclosures through machine-readable formats and the phased approach it has proposed. The success of the initiative will depend on global consistency, interoperability and clarity of implementation, as experience with regulatory reporting has shown that divergent interpretations and firm-specific implementations drive fragmentation and unnecessary costs.

Rather than creating new frameworks from scratch, the associations strongly encourage the publication of requirements not only as legal text but also as unambiguous, machine-executable logic, leveraging existing open-source, market-tested standards such as the Common Domain Model and ISDA’s Digital Regulatory Reporting initiative. This would promote consistent implementation, reduce duplication and long-term maintenance costs, improve data quality and support integration with other regulatory data sets.