The new frontiers of data lineage in banking

The ECB’s RDARR Guide has fundamentally elevated supervisory expectations for data lineage, compelling banks to deliver granular, attribute-level transparency across fragmented data landscapes. Many institutions have responded with large-scale remediation programmes that, while costly and difficult to maintain, often yield marginal business value. This paper examines why these approaches fall short and explores how banks can transition from principle-driven compliance toward a practical, defensible, and value-oriented implementation.

Drawing on supervisory practices, benchmarks, and industry dialogue, the paper highlights the persistent gap between regulatory intent and operational execution. It argues that exhaustive documentation is neither sustainable nor aligned with the spirit of supervision. Instead, banks must adopt a pragmatic, risk-based approach, concentrating lineage efforts where data risk is most acute and decision relevance is highest.

The paper introduces four operational levers - scope, granularity, end-to-end coverage, and execution - that banks can calibrate to balance compliance, feasibility, and commercial value. Furthermore, it outlines how emerging technologies, modern data platforms, and AI-enabled tooling are transforming data lineage from a manual burden into a sustainable capability embedded by design. Ultimately, the paper positions data lineage not merely as a mandate, but as a strategic asset that strengthens transparency, reduces long-term costs, and accelerates broader data modernization.

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