The European Banking Authority (EBA), European Central Bank (ECB) and European Insurance and Occupational Pensions Authority (EIOPA) have launched a consultation on DPM 2.1, proposing further changes to the data architecture underpinning supervisory reporting across the EU.
According to Regnology’s analysis, the update would take the Data Point Model (DPM) further away from static reporting templates and towards a shared, machine-readable approach to regulatory data. The analysis suggests this could change how institutions manage reporting, with greater emphasis on continuous data governance and centralised data foundations rather than recurring, template-led processes. The consultation is open until 30 September 2026, with the final version of DPM 2.1 expected in Q4 2026.
DPM 2.1 builds on DPM Refit and DPM 2.0, which established a common metamodel for organising regulatory reporting requirements. The latest proposals are intended to extend that framework rather than require a disruptive migration, drawing on practical experience and the needs of reporting across different regulatory domains.
The development of the ECB’s Integrated Reporting Framework (IReF), which is based on DPM 2.0, has also highlighted additional requirements for the metamodel. These are being addressed through DPM 2.1 as regulators seek greater alignment between statistical and supervisory reporting.
Among the proposed technical changes are explicit JSON taxonomies, which would provide a standardised, machine-readable format for exchanging metadata. The update also introduces more structured versioning and historisation, allowing changes to metadata to be tracked chronologically while retaining relationships between regulatory requirements.
Another key change is the separation of physical reporting templates from their underlying logical concepts. Rather than defining the same data point separately across different reporting modules, the model would allow it to be defined once and reused across multiple frameworks.
The proposals also cover versioning for item names and descriptions, compound properties, organisational hierarchies, physical and logical frameworks, module roles and origins, naming and labelling harmonisation, and support for property validation through regular expressions.
DPM 2.1 sits within the work of the DPM Alliance, which was established in 2024 by the EBA, ECB and EIOPA, with involvement from the Single Resolution Board. The Alliance provides governance for the DPM standard, while the Common Data Dictionary is intended to provide a shared foundation for regulatory concepts across different reporting requirements.
For banks and other financial institutions, a more connected data model could affect how reporting data is managed well beyond the production of individual reports. Linking regulatory requirements to reporting definitions, data points and technical reporting artefacts could provide greater traceability across the reporting process.
Regnology director of product management Erik Becker said, “The metamodel explicitly separates physical reporting templates from underlying logical concepts, allowing the same data… to be defined once and reused across completely different reporting modules.”
The proposed architecture could also support artificial intelligence applications across regulatory reporting. Regnology highlights areas including regulatory change management, automated impact analysis, semantic mapping and AI-assisted regulatory queries.
Structured links between legal requirements, regulatory concepts and data requirements could, for example, help identify reporting areas affected by a regulatory change. The same structure could also support mapping between new requirements and existing data or provide access to regulatory information through AI-assisted queries.
However, a machine-readable reporting environment would not eliminate the need for human involvement. Legal interpretation continues to depend on context and supervisory objectives, while AI-generated mappings and impact assessments would require review by regulatory experts.
For institutions, the proposed changes point towards greater investment in centralised data models, governance and traceability rather than relying on downstream adjustments to individual reporting templates. A reusable data foundation could support multiple reporting obligations across different frameworks, reducing the need to maintain separate structures for each one.
Regnology’s analysis ultimately frames DPM 2.1 as part of a wider move towards connected regulatory data, where information can be defined once, governed centrally and reused across reporting frameworks. For financial institutions, that could shift attention upstream towards the quality and structure of the data foundations supporting supervisory reporting, regulatory change management and emerging AI applications.
Read the full Regnology analysis
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Copyright © 2026 RegTech Analyst
