Navigating Dual Compliance: How Financial Institutions Can Thrive Amid EU-UK Regulatory Divergence in Securitisation Reporting

Introduction: The New Reality of Dual Compliance

The UK’s departure from the European Union has fundamentally reshaped the regulatory landscape for financial institutions, especially those active in the securitisation market. Where once a harmonised set of rules governed both the EU and UK, today’s institutions must navigate two distinct, evolving frameworks: the European Securities and Markets Authority (ESMA) in the EU and the Financial Conduct Authority (FCA) in the UK. This regulatory divergence presents both operational and technical challenges, but also opportunities for those who can adapt with agility and foresight.

The Challenge: Complexity and Risk in a Divergent Environment

For cross-border financial institutions, dual compliance is not simply a matter of duplicating processes. The FCA and ESMA frameworks, while initially similar, are diverging in both technical and operational requirements. This means:

Supporting both EU and UK-specific reporting requirements simultaneously
Ensuring seamless, compliant reporting for public and private securitisations in both jurisdictions
Maintaining high standards of data quality, validation, and transparency for all market participants

The risk of non-compliance, operational inefficiency, and increased costs is significant for any institution unable to adapt quickly and effectively. Legacy systems, manual processes, and siloed data architectures are ill-suited to this new environment.

The Solution: A Multi-Instance, Cloud-Native Platform for Dual Compliance

Publicis Sapient, in partnership with European DataWarehouse (EDW), has delivered a blueprint for thriving amid regulatory divergence. The answer lies in a modern, cloud-native, multi-instance platform that supports both ESMA and FCA requirements—ensuring operational efficiency, data quality, and future-proof compliance.

Cloud-Native, Scalable Architecture

At the heart of the transformation is a Microsoft Azure-based big data platform. This cloud-first approach enables real-time processing, validation, and storage of billions of loan-level data records. The platform’s scalability ensures that EDW can rapidly adapt to evolving requirements from both the FCA and ESMA, while maintaining high availability and robust security for sensitive financial data.

Multi-Jurisdictional Compliance Through Modular Design

The platform is purpose-built for flexibility, featuring multi-instance capabilities that allow EDW to efficiently manage separate regulatory regimes for the EU and UK. By reusing up to 80% of the core solution architecture, EDW accelerated its time-to-market for the UK repository, ensured operational consistency, and achieved significant cost efficiencies. This modular approach also means that future regulatory changes—whether in the UK, EU, or other jurisdictions—can be accommodated with minimal disruption.

Agile Delivery and Continuous Improvement

Publicis Sapient’s agile methodologies were critical in responding to frequent regulatory updates and technical changes. Through rapid iteration and continuous delivery, the platform remained compliant and user-friendly, even as requirements evolved. Automated DevOps pipelines and infrastructure-as-code practices further enhanced operational efficiency, enabling rapid deployment and consistent governance.

Enhanced User Experience and Data Quality

Advanced front-end technologies and automated data validation pipelines provide a seamless experience for issuers, investors, and regulators. Robust validation and quality assessment tools ensure that all submissions meet the stringent standards of both ESMA and FCA, supporting transparency and due diligence in both markets.

The Outcome: EDW as a Dual-Registered Securitisation Repository

On January 17, 2022, EDW was officially registered by the FCA as one of the first UK Securitisation Repositories, having already achieved ESMA designation in the EU. This milestone enabled EDW to:

Strengthen its leadership in regulatory reporting for both the UK and EU markets
Offer financial institutions a modern, compliant, and user-friendly platform for securitisation reporting
Support the financial ecosystem with high-quality, transparent data—bolstering investor confidence and regulatory oversight

Business Impact and Future-Readiness

The transformation delivered by Publicis Sapient and EDW has set a new benchmark for regulatory reporting in the post-Brexit era:

Scalability: The platform can process and validate vast volumes of data, supporting future growth and new asset classes
Operational Efficiency: Automation and cloud-native design reduce manual effort, lower costs, and enable rapid response to regulatory change
Market Confidence: Transparent, high-quality data empowers investors, issuers, and regulators to make informed decisions and maintain market integrity
Future-Proofing: The flexible architecture ensures that EDW can quickly adapt to further regulatory divergence or new compliance requirements in the UK and beyond

Practical Guidance for Navigating Dual Compliance

For organisations facing similar dual compliance challenges, several lessons emerge from the EDW transformation:

Invest in Modular, Cloud-Native Platforms: A flexible, scalable architecture is essential for managing multiple regulatory regimes and responding to change.
Embrace Agile Delivery: Continuous improvement and rapid iteration are critical in a dynamic regulatory environment.
Automate Data Validation and Reporting: Automation reduces compliance risk, improves data quality, and lowers operational costs.
Prioritise User Experience: Seamless, intuitive interfaces drive adoption and ensure that compliance processes are efficient and transparent.

Why Publicis Sapient?

Publicis Sapient’s role in the digital transformation of EDW’s regulatory reporting platform demonstrates its unique ability to deliver complex, cloud-based solutions tailored to the evolving needs of the financial sector. By combining deep regulatory expertise, advanced engineering, and agile delivery, Publicis Sapient empowers financial institutions to turn compliance challenges into opportunities for innovation and growth.

As the UK and EU continue to define their regulatory identities post-Brexit, Publicis Sapient stands ready to help financial institutions navigate change, ensuring they remain compliant, competitive, and future-ready in a dynamic market.

Ready to transform your regulatory reporting capabilities for a dual compliance world? Connect with Publicis Sapient’s experts to discover how agile, cloud-native solutions can future-proof your business and drive sustained compliance and growth.