Digital Regulatory Reporting (DRR) has gained momentum as the industry looks to replace fragmented, firm-specific interpretations of reporting rules with a shared, machine-executable model that consistently links regulatory requirements to the data used to fulfil them. Rather than relying on templates, local mappings and bespoke logic embedded deep within legacy systems, DRR provides a common framework for expressing how each field should be derived and validated, ensuring that granular reporting is interpreted the same way across firms and jurisdictions. Driving this shift are the technical specialists who seldom make headlines but who sit closest to the complexity: the engineers and standards experts who translate regulatory text into executable rules, reconcile legacy data structures with the Common Domain Model, and lay the groundwork for a more coherent, transparent reporting ecosystem.
One of the most influential of these behind-the-scenes specialists is Barcelona-based TradeHeader, a specialist consulting firm founded in 2011 by Marc Gratacós – formerly ISDA’s first full-time employee dedicated to FpML. The company has grown to become a go-to engineering partner for institutions adopting DRR, implementing the Common Domain Model (CDM), or standardising data across front-to-back processes. Its evolution reflects both the complexity of regulatory reporting and the practical work required to modernise it.From Standards Stewardship to Engineering Partner
TradeHeader’s roots are firmly tied to the standards community. Gratacós began his career at ISDA supporting the FpML working groups, gaining early exposure to how industry data models are shaped. When he later established TradeHeader, he carried that ethos forward: the firm would not simply use industry standards but actively participate in developing them. That commitment now extends across FpML, FIX, ISO 20022, and CDM working groups, giving TradeHeader early insight into emerging requirements and enabling it to contribute directly to the specifications its clients depend on.
“We were participating in the different working groups that developed the standards,” he recalls. “We also expanded to FIX and ISO 20022… and we have been expanding on that. We also participate now in the Common Domain Model with FINOS.”
This continuity has proved strategically valuable. While many consultancies focus on post-trade or regulatory projects, few have the same architectural insight into how the standards are designed and implemented across multiple jurisdictions. This gives TradeHeader the ability to guide clients not just on compliance requirements but on how the underlying models, functions and lifecycle logic are intended to operate.
The Cost of Fragmented Interpretations
What stands out most in conversation is Gratacós’s candid view of the inefficiencies embedded in today’s reporting processes. Firms maintain sizeable teams of analysts, compliance specialists and technologists who all work through the same interpretive questions in parallel. Each institution independently resolves regulatory ambiguities, builds its own mappings from internal systems to reporting outputs and expends scarce SME capacity on problems that are effectively shared across the market.
“The same questions they have in terms of how I need to report this field are the same questions that everyone has,” he notes. “They’re spending a huge amount of money on things that should be solved by just sitting together and agreeing on an interpretation.”
This captures the core premise behind DRR: reporting should be anchored in a common, machine-executable interpretation of the rules rather than in firm-specific logic. Instead of maintaining divergent implementations across jurisdictions, firms should operate from standardised event-level data and rely on shared code to derive the required outputs. Regulators, in turn, can concentrate on analysing consistent data rather than responding to inconsistent submissions.
CDM as the Functional Backbone
One reason TradeHeader sits at the centre of the DRR conversation is its expertise in the functional layer of the FINOS Common Domain Model (CDM). CDM is often misunderstood as another data model, but its real value comes from representing events, state transitions, valuations and lifecycle behaviours in a machine-executable form.
“In the CDM you have a functional language,” says Gratacós. “You’re able to represent not only the actual data of a product, but also how functionally that product works… you can represent the changes of states in the actual product.”
The model’s extensibility is already evident with the International Capital markets Association’s successful completion of its CDM project for Repos and Bonds in February 2023, and with the International Securities Lending Association (ISLA) which is looking to extend the DRR model to cover SFTR reporting for securities lending.
TradeHeader is directly involved in these efforts through its client projects where in one engagement, a firm used CDM to bring OTC, listed and fixed income data onto a single representation for EMIR reporting. Gratacós explains that once the data was aligned, the client could “see applications where we can actually see common representation of the products,” enabling “much more complex processing” across functions such as valuations and margin calculations.
POCs Across Jurisdictions and the 80–85% Rule
According to Gratacós, around “10–15 institutions” are running proofs-of-concept across EMIR, CFTC and Asia regimes. He expects the first groups to move into full production over the coming year, with DRR logic extended across multiple regulations shortly thereafter.
Perhaps the most significant insight from these POCs is the level of reuse. “We are having a huge amount of reusability,” he says. “It’s around 80 to 85%… but you still need the remaining 15%.”
That final 15% – the jurisdiction-specific nuance – consumes the most effort. But the efficiency gain from reusing four-fifths of reporting logic across markets creates a compelling case for shared interpretation frameworks, joint utilities and collaborative DRR initiatives.
Toward Explainable, Traceable Regulation
TradeHeader is “actively exploring” traceability – mapping how regulatory text, CDM components and executable logic relate to one another, and understanding how each change ripples through a firm’s reporting architecture. Trusted data and open standards form the backbone for both compliance and emerging AI use cases – see Gratacós recent post following A-team Group’s RegTech Summit in London. DRR and the CDM sit at the centre of that foundation – providing the structured, interoperable frameworks needed to support auditability, consistency and safe automation. By linking regulatory intent to machine-readable logic, and ensuring that data is represented in an open, well-defined model, firms can build reporting and AI capabilities on infrastructure designed for transparency rather than fragmentation.
Regulators, too, are beginning to engage. Supervisory bodies such as the FCA, MAS and HKMA have quietly attended TradeHeader’s CDM-related training sessions to deepen their understanding of the model and its implications. While Gratacós emphasises that regulators are cautious about endorsing specific technologies, their involvement signals a shift: supervisors increasingly want to understand how firms derive reporting outputs.
A Practitioner’s Path to Reporting Reform
As the industry moves steadily toward shared models, machine-executable rules and event-driven data architectures, firms like TradeHeader – highly focused, and standards-native – will become increasingly relevant for an industry carrying a high technical debt load in its interaction with regulatory agencies. Their work demonstrates that DRR is not a distant aspiration but a practical, incremental shift already underway, in which collaboration, common interpretation and functional modelling matter at least as much as technology.
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