The Banco de España has defined the necessary actions to address the recommendations formulated in the evaluation report. The main recommendations and the actions that the Banco de España commits to undertake in response are detailed below.
Theme I: Data fundamentals
Recommendation 1: The Banco de España should adopt a comprehensive, multi-year data strategy that aligns with the Bank’s general and technology strategies and is backed by a specific roadmap, milestones and a budget. The business areas’ priorities should be the basis for ensuring the strategy’s ongoing relevance and effectiveness.
- A three-year Data Strategy is being developed that addresses the Bank’s needs, as set out in the Strategic Plan 2030, and is in line with its technology strategy. This will include implementation milestones and mechanisms to monitor its progress and evaluate its performance. It will also set out procedures to simply and swiftly manage data requests from business areas by means of a centralised platform and offer sustained dialogue to understand their requirements.
Recommendation 2: Executive empowerment of the Chief Data Officer and the Data Office. The functions and actions of the Data and Users Committee should be strengthened to support the data strategy’s implementation. The Banco de España should establish a data governance framework with defined roles and responsibilities, a data catalogue, procedures for quality management and shared processes for metadata, reference data and master data.
- The need to empower the Data Office to centralise and coordinate its functions effectively will be studied, as will the current responsibilities of the Data and Users Committee, to determine whether additional committees and/or groups are necessary.
- Awareness-raising initiatives will be carried out to publicise the recently approved Data Policy. Formal groups with similar responsibilities will also be established in different areas of the bank, including a Data Stewards group.
- A governance framework will be implemented, with a data catalogue, a metadata standard, master and reference data, terms of use for data gathering and a quality programme. This framework will also cover artificial intelligence data governance.
Theme II: Technology
Recommendation 3: The data strategy should be aligned with the technology strategy and business priorities. The Banco de España should decide on its cloud strategy. It is necessary to replace legacy systems and develop a strategy for the data lake, first defining a Bank-wide data model, with a data catalogue acting as an inventory of all data assets. Data governance, quality and security practices should be integrated into the Bank’s systems and applications.
- A five-year technology strategy has been developed (and integrated into the Strategic Plan 2030 under the Technology pillar), which is in line with business priorities and the Data Strategy. Among other initiatives, it includes the adoption of a hybrid cloud and the launch of an application modernisation plan to replace, within five years, applications that handle 70% of data volume.
- As part of the Strategic Plan 2030, a data lake strategy will be defined and approved, containing a detailed plan for the gradual incorporation of the target collections. Once these collections are identified, their catalogue will be listed and published. In parallel, a data model will be defined to be shared by the entire Bank.
- New collections will be protected through security measures, anonymisation and access controls. Automated processes are being applied to ensure quality, and additional technological solutions (governance tools and a virtualisation platform) will be implemented.
Recommendation 4: The Banco de España should increase its overall investment in information technology (IT) to fund the replacement of legacy systems and accelerate the adoption of cloud-based technologies (see Recommendation 3). It should also invest in its IT workforce, bringing in professionals with experience in the cloud, data lakes and data governance systems to reduce reliance on external providers.
- Approval has been given for an updated governance structure for technological projects and investments with improved cost reporting to enhance business areas’ understanding of their technological costs. An advanced cloud cost control model (FinOps) has also been implemented, which is in line with this framework.
- A recruitment process for IT experts has concluded, resulting in the hiring of professionals with experience in cloud-based architecture design, data lake management and the implementation of data governance management systems. Another recruitment process is under way for data scientists.
Theme III: Talent
Recommendation 5: The Banco de España should improve data literacy and identify specific data-related competences for both current and future roles. The description of any position involving data management and use should include the relevant competences and technical skills in this field.
- Under the Strategic Plan 2030 the Bank will set up a new role architecture that will include specific data competences. Once it has been defined, data-related requirements will be incorporated across all the Bank’s selection processes.
Recommendation 6: The Banco de España should implement a data training strategy in phases to enable all its staff to develop basic competences in data. It should also explicitly link qualification certificates and training modules to the specific competences of the different roles.
- As part of the Strategic Plan 2030, data and AI academies will be created, with a basic itinerary that will be mandatory for all staff, an intermediate itinerary and an advanced itinerary for experts. The academies are to be launched simultaneously or in quick succession. Also, training will be linked to the competences associated with various roles, so that employees can clearly identify the skills they need.
Recommendation 7: The Bank could consider expanding the hiring of internship students, offering a sequence of summer internships over several years to groups in an earlier educational stage. It could also implement a structured data-related talent rotation programme for highly skilled employees. In addition, the Bank should continue to organise internal hackathons and launch other projects focusing on data with external collaboration. Moreover, its role descriptions and workload planning should explicitly include training, exchange of knowledge, innovation and collaboration. Since the adoption of market-equivalent salaries poses legal challenges, the Bank should explore alternative compensation schemes to attract and retain specialised data talent.
- Under the Strategic Plan 2030, there are plans to organise an annual hackathon for Banco de España staff, with the participation and support of external collaborators. The first event was held in September 2025.
- As part of the role definition process, descriptions should include data-related activities, such as training, knowledge exchange, innovation and collaboration.
Theme IV: Culture
Recommendation 8: The Bank’s Data Portal should be more accessible, better organised, easy to use, up-to-date and should have user support, helping employees remain informed and aligned (push and pull format). It should also foster cross-departmental data communities to break down the silo culture. Data should be considered a shared organisation-wide asset, rather than the exclusive property of individual departments. There should be clear policies to balance the level of protection with an appropriate exchange of data.
- The Data Portal, which was set up under the Strategic Plan 2030, includes all the Bank’s information on data production and analysis, ensuring it is available and accessible to all employees. Additionally, a dedicated space will be enabled to share data analysis code.
- The Data Strategy will incorporate the need to create data communities and define a communication plan to raise awareness among employees on the importance of data and data sharing.
- The Security Policy and Data Policy will be brought into line with each other. The terms of use for collections and the criteria for anonymising sensitive information will also be incorporated.
Recommendation 9: The Bank should promote a mindset that values improvement over perfection. Management should regularly communicate this culture of learning through controlled experimenting, as in sandbox and hackathon environments. An effective practice is to focus on incremental progress, using the 80/20 rule or Pareto principle.
- One of the initiatives of the Strategic Plan 2030 envisages the redesign of processes and the consolidation of a culture of continuous improvement among teams, through different actions. These include creating a community and a wiki on continuous improvement, developing a framework to foster risk acceptance in the organisational culture and launching innovation processes.
Recommendation 10: The Banco de España should recognise and address the challenges posed by its highly complex structure, which requires, among other things, a higher level of specific mentoring, consistency and alignment of daily data-related activities with its strategic goals. These challenges should be broached as part of a cultural and organisational revision. Also, cross-functional work teams should be formed to encourage a shared understanding of data, incentivising participation and regularly evaluating collaborative results.
- New organisational approaches have been introduced under the Strategic Plan 2030, including matrix governance and cross-departmental teams, which help eliminate silos.
- An analysis will be conducted on the formation of cross-functional working groups to foster a shared understanding of data.
- The Data Office will continue to promote and support actions for managing change in all matters relating to the data culture.
