Proposed directive relating to the version of BA returns that form the basis for reporting by auditors

For banks and their external auditors, the practical issue is version control: reporting teams and audit teams must be aligned on the exact return set, data definitions and submission lineage used to support audit conclusions. This is not a major policy overhaul, but it is a meaningful supervisory clarification because inconsistent return versions can create audit evidence gaps, reporting discrepancies and avoidable regulatory scrutiny. Compliance, finance and internal audit teams should review the draft, confirm which BA return versions are currently relied on, and tighten change-control and evidence trails before the directive is finalised.

Banks should also coordinate early with external auditors so that reporting packs, reconciliations and sign-offs reference the same return version. The consultation may present an opportunity to reduce ambiguity, standardise audit evidence and strengthen prudential reporting governance. Firms should monitor for the final directive and any accompanying implementation expectations.

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