Why Data Quality is Becoming the New Regulatory Battleground

Firms have invested enormous amounts of time, resources and expertise into regulatory reporting change. Reporting frameworks have been rewritten, data standards have evolved and operating models have been redesigned to meet new requirements.

For many firms, success was measured by implementation: understand the rules, deliver the changes and meet the deadline. Increasingly, regulators appear to be shifting their focus from the implementation of reporting frameworks to the integrity and quality of the data those frameworks produce.

 

Enforcement Actions Are Putting Data Quality in the Spotlight

A recent enforcement action by ASIC highlights why: in July 2026, the Australian regulator imposed an A$2 million penalty on Deutsche Bank after identifying reporting errors affecting more than 260,000 OTC derivatives transactions.

The issue centered on inaccuracies in a field used to identify the buyer and seller in a trade. On the surface, that may sound like a technical issue, yet ASIC concluded the errors impaired its ability to accurately monitor market risk and exposures. The concern was not whether transactions were reported, but whether the data being reported could be relied upon.

Increasingly, regulators appear to be shifting their focus from the implementation of reporting frameworks to the integrity and quality of the data those frameworks produce.

As reporting regimes mature, the conversation appears to be shifting from whether firms can report to whether they can demonstrate the quality of what they report. When critical data contains gaps, inconsistencies or inaccuracies, it limits regulators' ability to build a clear view of market activity and exposure.

Nor is this trend confined to Australia. Across major jurisdictions, regulators have spent years driving greater harmonization through common reporting standards and data models. As those frameworks mature, it is only natural that attention turns to the quality, consistency and reliability of the data being submitted.

This evolution is also reflected in ASIC's proposed CS48 amendments. While intended to simplify reporting and address practical implementation challenges, the changes further align Australia's regime with international standards, provide greater clarity around reporting obligations and support more consistent, usable data.

Although implementation has been deferred beyond March 2027, the broader message remains unchanged: regulators are increasingly focused on the quality, consistency and usability of the data firms submit.

 

Reporting is No Longer the Finish Line

In conversations with clients, I often hear that although reporting programs were delivered successfully, there is less confidence in the sustainability of some of the processes underpinning them. Compressed implementation timelines often meant firms focused on achieving regulatory compliance first, with optimization, simplification and long-term sustainability becoming secondary priorities. While those decisions were often necessary to meet regulatory deadlines, maintaining them over the long term can be challenging.

When critical data contains gaps, inconsistencies or inaccuracies, it limits regulators' ability to build a clear view of market activity and exposure.

 

Demonstrating Control, Not Just Compliance

As a result, many firms are stepping back and asking broader questions:

• Where does critical reporting data originate?
• How quickly can issues be identified and resolved?
• Is ownership and accountability clearly defined?
• Can reporting quality be demonstrated consistently over time?

 

These are not simply compliance questions; they speak to operational resilience, governance and confidence in the information firms use to make decisions every day. That is why I believe data quality deserves a much higher place on the strategic agenda. Strong governance, clear ownership, effective controls and robust monitoring are becoming just as important as the reporting obligation itself.

We've seen this firsthand in DTCC Consulting. Following recent ASIC activity, there has been a noticeable increase in firms reassessing their reporting controls, data quality processes and broader regulatory reporting frameworks. Across APAC, conversations increasingly focus on the same challenge: how to build reporting environments that are not only compliant, but trusted, sustainable and capable of standing up to greater regulatory scrutiny.

Strong governance, clear ownership, effective controls and robust monitoring are becoming just as important as the reporting obligation itself.

Ultimately, regulators are looking for reporting they can rely on. For firms, the challenge is no longer simply meeting their reporting obligations. It is demonstrating that the data underpinning those reports is accurate, controlled and fit for purpose.

 

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