- Research Article
- 10.47473/2020rmm0165
Bridging RDARR and credit risk models: a data lineage-driven framework for sound data governance
- Apr 01, 2026
- Risk Management Magazine
- Alessandro Di Maria + 2 more +2
The effective implementation of the Risk Data Aggregation and Risk Reporting (RDARR) principles introduced in 2013 by BCBS 239 continues to pose significant challenges for banking institutions, particularly in ensuring consistent interpretation and application across complex reporting domains. More than a decade later, the European Central Bank (ECB) has reinforced and broadened the scope of these principles through increasingly prescriptive supervisory expectations, following persistent implementation gaps. This paper aims to interpret the RDARR principles and, through a practical example, outline the changes and requirements necessary to achieve full compliance for credit risk models. In doing so, this study first provides a mapping matrix to determine which credit risk models are RDARR-relevant, as this represents a necessary prerequisite for a consistent and risk-based application of the framework. Then, it focuses on Pillar I credit risk models, which are among the most advanced in terms of data quality and data architecture, owing to the regulatory frameworks established by the ECB and EBA. Building on this starting point, the paper analyses the main gaps in the application of RDARR principles and proposes a remediation framework for Pillar I models that attempts to mitigate the compliance burden often associated with RDARR. In particular, it leverages the introduction of an end-to-end data lineage concept as a key enabler to strengthen data governance and support the systematic integration of data quality controls aligned with ECB expectations. The proposed framework, developed for Pillar I models, serves as a benchmark for the broader set of credit risk models identified through the matrix, guiding their progressive alignment with RDARR principle
Read more