Summary
Details
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Institutions authorised by BCB in S1–S4, with staggered effective dates.
S5 institutions are not required to remit this information under Resolution 151.
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What’s Required
1) Determine segment and applicability, then implement reporting readiness
BCB Resolution 151 applies to financial institutions and other institutions authorised by BCB in segments S1–S4, with segment-based start dates. Segment S5 is not included in the submission obligation. Institutions must map their segment classification and ensure the reporting pipeline is live ahead of the first applicable database date.
2) Submit the DRSAC information set as defined by BCB instructions and layouts
The rule establishes an obligation to remit information related to social, environmental, and climate risks, connected to the broader risk management and PRSAC frameworks. In practice, submission relies on:
the DRSAC reporting document itself (code 2030 referenced in BCB reporting instructions)
technical layouts and completion instructions that specify fields, definitions, and validation logic
updates to instructions via BCB normative acts (for example, the BCB has issued instruments updating DRSAC layouts and instructions)
3) Establish internal governance for regulatory reporting quality
DRSAC is supervisory reporting. Institutions should treat it as a regulated return similar to other prudential submissions, requiring:
ownership in regulatory reporting or finance/risk reporting functions.
documented source systems and transformation logic.
controls for completeness, accuracy, reconciliation, and sign-off.
change management when BCB updates the layout or definitions.
Weak governance often manifests as late submissions, inconsistent series, or unexplained revisions that can trigger supervisory attention.
4) Align DRSAC content with internal risk management under CMN 4,943 and PRSAC under CMN 4,945
A critical compliance expectation is consistency across:
internal risk identification and measurement (CMN 4,943)
PRSAC principles and actions (CMN 4,945).
public disclosures (GRSAC under BCB 139).
supervisory reporting (DRSAC under BCB 151).
Supervisors can and do compare these layers. If DRSAC indicates material risks but public disclosures downplay them, or if PRSAC is generic but DRSAC reveals concentrated exposures, institutions may face follow-up and remediation demands.
5) Data classification and definitional discipline
DRSAC reporting inevitably requires classification decisions such as:
identifying exposures that relate to environmental or climate risk drivers.
mapping clients, sectors, and geographies to risk categories.
tracking changes over time and explaining drivers (portfolio shifts, methodology changes).
Institutions should maintain a data dictionary, a decision log for classification, and evidence for any methodology updates, because the BCB may ask for explanations for breaks in series.
Important Deadlines
Date of adoption: 6 October 2021.
Segment-based first submission start dates (by database):
S1: from December 2022
S2: from June 2023
S3: from December 2023
S4: from June 2024
Updates to reporting instructions/layout: BCB has issued normative instruments updating DRSAC instructions and layout, affecting documents prepared from specific database dates.
Current Status
In force and operational, with reporting cycles active across segments S1–S4 and technical maintenance through BCB instruction updates.
Penalties for Non-Compliance
As a BCB supervisory reporting obligation, enforcement typically includes:
Supervisory findings for late, missing, or inconsistent submissions.
requirements to correct and resubmit.
Escalation to administrative measures if failures are persistent, material, or suggest weak governance and controls.
The practical impact can include expanded supervisory scrutiny, remediation costs, and reputational risk with regulators. For regulated entities, recurring reporting failures can also be interpreted as broader weaknesses in controls and governance.
Examples of Known Violations
Typical DRSAC reporting failures include:
Late or missing submissions due to unclear ownership or weak reporting calendars.
Inconsistent methodology across reporting periods without documentation, causing unexplained shifts in reported indicators.
Classification errors, such as mis-mapping counterparties or exposures to risk categories, later lead to large revisions.
Reconciliation gaps where DRSAC indicators are not reconcilable to internal risk reports or portfolio data.
Layout non-compliance after BCB updates instructions, producing validation errors or rejected files.
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