Thought Leadership

When the Basel Committee introduced the BCBS239 principles in 2016, their scope was limited to systemically important banks. These BCBS239 principles aim to ensure that banks are truly in control of their data. Yet, implementing them and addressing findings from on-site inspections requires significant resources and costs. For many institutions, BCBS239 has long been seen as a regulatory burden rather than a source of business value. But is that perception accurate?

From Compliance to Competitive Edge

Over the past decade, banks have increasingly positioned themselves as digital organisations, embracing data-driven decision-making. The promise? Faster customer service, streamlined operations, and lower costs. The assumption is simple: data consists of raw facts, and fewer manual interventions mean quicker decisions.

However, reality is more complex. Data entry happens within a context linked to the purpose of its use, the historical timeframe, and the jurisdiction where it was recorded. For example, the term collateral meant something different in the past than it does today, not least because the ECB did not exist then, and French regulations differed from Dutch regulations. Complexity multiplies when banks merge, and each integration introduces new definitions. Additionally, the development of new financial products, such as green loans, over time may lead to changes in existing definitions or the creation of new ones.

The Case for Strong Data Governance

To become truly data-driven, organisations must harmonise, document, and actively maintain data definitions across the enterprise. This is not a one-off exercise; it requires ongoing policy, resources, and governance. While drafting governance frameworks is relatively easy, implementing them is the real challenge.

Typically, governance starts top-down, often from a CFO and reporting perspective, but execution lies with teams responsible for data capture, integration, and usage. Continuous collaboration between data owners and data users is essential. Here, BCBS239 provides valuable guidance. The key is to avoid creating a bureaucratic maze and instead strike a balance between compliance and practical business needs.

Beyond Regulation

BCBS239 is more than a regulatory checkbox. When implemented thoughtfully, these principles can help banks achieve better data quality, faster decision-making, and stronger operational resilience. In an era where data is a strategic asset, these benefits extend well beyond compliance and should be seen as a source of competitive advantage.

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Author: John Zoetekouw, CubeMatch Benelux CEO