At its meeting on 28 and 29 September 2026 the Basel Committee approved the final standard for machine-readable Pillar 3 disclosures, with publication due around the end of the year. The EU has run the experiment since January, and UK firms have one reporting cycle left.
In brief: at its meeting on 28 and 29 September 2026 the Basel Committee approved the final standard for machine-readable Pillar 3 disclosures, and says the standard will be published around the end of the year. It changes nothing about what banks disclose and everything about who can read it, because quantitative disclosures become structured data that anyone can aggregate, which the EU already made routine when the EBA Pillar 3 data hub went live on 28 January 2026. For UK firms the new disclosure rules in PS11/26 take effect on 1 January 2027 against a first reference date of 31 December 2026, so the preparation window is the quarter now running.
A PDF conceals inconsistency. A tagged dataset publishes it.
That is the whole of what the Basel Committee agreed in Indonesia on 28 and 29 September 2026. The Committee approved the final standard for machine-readable Pillar 3 disclosures and said it will publish around the end of the year. The consultation behind it, issued on 5 December 2025 with comments due by 5 March 2026, was unusually direct about the problem: most banks currently publish their disclosures in PDF format only, which makes it difficult to aggregate, process and compare data across banks. The fix introduces a requirement and technical specifications for machine-readable quantitative disclosures without changing the underlying disclosure requirements at all.
Executives tend to file that under reporting plumbing. It is not. A disclosure that can be queried can be reconciled against every other number the firm publishes, by a supervisor, an analyst or a competitor, at no cost and without asking.
What the Committee approved, and what it left to national discretion
Three features of the standard matter commercially.
The scope is quantitative. Narrative disclosure is untouched, which means the parts of Pillar 3 that currently absorb the inconsistency, the explanatory paragraphs, will not travel with the data.
The requirements do not change. There is no new metric to calculate, so no programme budget to argue for, and no comfortable implementation runway attached to a rule change.
Publication is a national choice. Supervisors decide whether banks publish machine-readable disclosures on their own websites or through a centralised data repository. Firms operating across jurisdictions should expect both answers.
The same meeting agreed to review the sufficiency and adequacy of existing event type loss categories in the operational risk framework, with a focus on cyber risk and AI developments. Read the two decisions together and the direction is clear: supervisors are rebuilding the categories they measure firms with, and moving the evidence into formats they can process at scale.
The EU has already run this experiment
European firms can describe what happens next, because it has happened to them.
Date
Jurisdiction
What changed
26 and 28 January 2026
EU
Large and other institutions began submitting on 26 January and the EBA Pillar 3 data hub went live on 28 January, carrying prudential information from all EEA institutions on one platform, with a visualisation tool for comparison and bulk download for research
June 2026
EU
Full data set for the first three reference dates, June, September and December 2025, expected to be available
8 June to 20 July 2026
EU
EBA discussion paper proposing that it collect, calculate and publish Pillar 3 disclosures for small and non-complex institutions itself, with responses due by close of business on 20 July
28 and 29 September 2026
Global
Basel Committee approves the final machine-readable standard, publication expected around the end of the year, with the website or repository question left to national supervisors
1 January 2027
UK
PS11/26 disclosure rules take effect, first reference date the period ending 31 December 2026, first publication in the first half of 2027; Basel 3.1 applies from the same date under PS1/26, with FRTB-IMA templates deferred to 1 January 2028
The EBA has gone a step further than the Basel standard requires. Its June proposal would have the regulator calculate and publish disclosures for small and non-complex institutions on their behalf, which removes the burden and the discretion in the same move. That is the end state of structured disclosure: the supervisor holds the data, and the firm's role is to be consistent with it.
Structured disclosure is a lineage test with an audience
The shift is in who can find a discrepancy.
What becomes machine-readable
Who can now check it
What it exposes if governance is weak
The same quantitative template across consecutive reference dates
Anyone with the published series
Silent restatements. A figure that moves without a stated reason becomes a question at the next results call
Disclosure figures alongside the regulatory returns they derive from
Supervisors, and increasingly analysts
Disclosure and return produced by different teams from different extracts, reconciled by narrative rather than by lineage
Peer group data in identical structure on one platform
Competitors, investors, researchers
Outliers found by a script in minutes rather than by an analyst over weeks, with no chance to frame the number first
Standardised MREL templates UK KM2 and UK MREL 1 to 3, replacing free-form disclosure for mid-tier firms
Any reader of the UK rulebook
Firms that have never published these figures in a fixed shape finding their source data was never defined to that granularity
The Pillar 3 basis statement, naming which disclosure regime applies to the firm
Every user of the disclosure
Ambiguity about scope and frequency that used to absorb inconsistency
Every row is a BCBS 239 principle with an external audience attached. Accuracy, completeness, timeliness and adaptability stop being supervisory self-assessment language and become observable properties of a published series. A firm that cannot explain a movement in a tagged figure is not judged to have a tagging problem.
The UK window is the quarter you are in
PS11/26, published on 26 March 2026, applies to PRA-authorised banks and building societies, PRA-designated UK investment firms and CRR consolidation entities. It replaces free-form MREL disclosure with the UK KM2 and UK MREL 1 to 3 templates, adds a narrative on capital distribution constraints inside UK CC1, and requires firms to state which disclosure regime applies to them. It takes effect on 1 January 2027 for a first reference date of the period ending 31 December 2026, with publication in the first half of 2027. Basel 3.1 lands on the same day under PS1/26 of 20 January 2026.
So the data that will fill the first set of new UK templates is being generated now. That is the practical point for a board. The question is not whether the firm will comply in 2027; it is whether the Critical Data Elements behind each template line have a named owner, a source system of record and a quality threshold during the period being measured, because retrospective reconstruction is exactly the practice that structured publication makes visible. Under SM&CR somebody is already accountable for the disclosure. They should be able to say which of those three things is missing.
Five questions before the next board meeting
Who owns the Pillar 3 submission as a data product, and does their statement of responsibilities say so?
If an outsider placed our published Pillar 3 figures beside our regulatory returns, would they reconcile without explanatory narrative?
Which Pillar 3 line items sit on our Critical Data Elements register today, with an owner, a source system and a threshold that triggers action?
For the 31 December 2026 reference date, will the new UK templates be produced from a controlled pipeline or assembled by hand?
Now that our EEA peers are published in a single comparable structure, who inside the firm reads that data about us before an investor does?
Once a disclosure can be queried, it stops being a document about the firm and becomes evidence about its controls.
