Redefining Digital Regulatory Reporting with CDM & DRR

Regulatory reporting is evolving from static data submissions to dynamic, process-driven compliance. At the core of this shift are the Common Domain Model (CDM) and Digital Regulatory Reporting (DRR), which together define a shared, machine-executable framework for how financial transactions are represented and reported. By standardising both data and process, they enable a consistent interpretation of regulatory rules, embed controls directly into transaction workflows, and create auditable, event-based records that regulators and firms can rely on. This approach establishes the foundation for a fully digital, verifiable regulatory ecosystem.

Common Domain Model (CDM)

At the heart of the CDM lies an event-oriented lifecycle architecture – the model is built to capture how financial transactions evolve through state transitions, rather than simply capturing static data snapshots. A “business event” in the CDM denotes a state change of a transaction – e.g. trade execution, confirmation, affirmation or a lifecycle amendment – and each such event produces a new trade-state instance, enabling reconstruction of the full sequence of actions and the causal lineage of any position or reportable outcome.

By codifying the logic of processes alongside the data itself, CDM enables a common understanding of the digital ecosystem for firms and regulators alike. This shared model reduces duplication, interpretation risk and reconciliation breaks.

Designed to be extensible from the outset,  CDM has been adopted by the International Capital Market Association (ICMA) for repos and bonds and by the International Securities Lending Association (ISLA) for securities lending.

The CDM is now under the governance of the Fintech Open Source Foundation (FINOS), where a CDM Tokenized Assets Working Group is extending the model for tokenised assets and settlement while preserving core CDM logic. While trade workflows typically use FIX, and ISO 20022 is widely used across post-trade and reporting, the CDM can serve as the canonical post-trade lifecycle representation and a bridge between such protocols and regulatory reporting.

Digital Regulatory Reporting (DRR)

DRR  translates regulatory rules from human-readable text into machine-executable logic using the CDM as its foundation. This initiative, also developed and maintained by ISDA, allows participants to encode reporting requirements once, in an open and transparent format, and apply them consistently. DRR has already been implemented for the CFTC  Rewrite and the EMIR Refit, with further extensions under way.

From the ISDA website : “ISDA is committed to supporting 12 core regulatory reporting regimes across nine jurisdictions: the US (under Commodity Futures Trading Commission (CFTC) rules), the EU (under the European Market Infrastructure Regulation (EMIR) and the Markets in Financial Instruments Regulation (MIFIR)), the UK (under UK EMIR and UK MIFIR), Japan, Australia, Singapore, Hong Kong, Canada and Switzerland. The ISDA DRR is freely available to all firms.”

At the same time, the UK’s Financial Conduct Authority (FCA) and Bank of England (BoE) have advanced their own DRR efforts through the Transforming Data Collection (TDC) programme. This work re-examines the entire regulatory data lifecycle – how data is collected, validated and used – to ensure that supervisors receive the information they need in a timely, standardised and low-cost way. Both tracks share the same philosophy: rules and reporting obligations should be digitally verifiable, not subject to repeated manual interpretation.

Data Meets Process

Whilst data is the foundation of all things digital, it’s where data meets process that digital systems deliver value and where controls can be embedded directly into the firm’s core business.

The process logic within CDM allows DRR to bind regulatory rules directly to business events, making compliance part of the transaction lifecycle rather than an after-the-fact check and remediation. This integration enables compliance to transition to a continuous, process-driven activity, with validation and lineage built into in the design.

This convergence of data and process means each life-cycle event carries its own audit trail with embedded checks and regulatory reporting logic. For firms, this means fewer reconciliation breaks and greater operational clarity. For regulators, it delivers data that is more accurate, timely and comparable across markets. For the broader ecosystem, it establishes a foundation for transparency and trust – where evidence of compliance is inherent in the process, not layered on top of it.

CDM defines both data and process, providing context where agentic AI can act as an intelligent participant within a governed ecosystem, delivering automation without losing traceability. The result is an operational environment where humans, systems and supervisory bodies share the same digital context, improving both assurance, agility and transparency.

CDM and DRR extensibility have been proven beyond OTC derivatives, with implementations for Repos and Securities. These markets rest heavily on collateral management requiring CDM to accommodate multiple asset classes including listed securities.

Decades of deeply embedded market infrastructure, bespoke workflows, and legacy technology can’t be unwound overnight so it remains to be seen if and when traditional listed asset classes make the transition to the CDM/DRR model but the foundations for a digitally transformed regulatory ecosystem are in place.