Banking Group Governance Maturity · BCEAO Instruction on Consolidated Supervision
Your group framework assessed against consolidated supervision requirements, and turned into a roadmap.
10 themes, a 5-level scale. And the action that moves each level to the next.
The framework’s 10 themes, already written from L1 to L5. One company, one business unit, or 300 at once.
Banking Group Governance Maturity · BCEAO Instruction on Consolidated Supervision
10 themes, 5-level scale.
Nordhavn Industries
53 / 100
They measure their maturity with Datamensio
An example
This could be your situation.
Take one company as an example: three sites, three spreadsheets, no shared answer.
Nobody can consolidate.
Nordhavn Industries, 2,400 people in Hamburg, Lyon and Porto. A client asks where the group stands. Each site answers in its own spreadsheet, with its own scales.
Three weeks, a single base.
One BCEAO Instruction on the consolidated supervision of banking groups (WAEMU), read alongside the WAMU banking law and the Basel II/III WAEMU prudential framework assessment launched across all three sites at once, from the managers’ interview notes. The framework was already written, its 10 themes and levels L1 to L5 too.
Two costs avoided before being committed.
A score of 53 out of 100, with the gap concentrated on three themes. The AI companion spotted that two actions duplicated those of another audit. The committee report took one sentence to request.
What it saved them
- 3sites measured on the same base, instead of three questionnaires to reconcile
- 2duplicate actions caught before the spend
- 1committee report, with no manual rework
These figures are an example. They could be yours.
The standard imposes processes. Datamensio says where you stand.
01
The framework is already written
Themes, questions and levels L1 to L5, all written. You do not start from an empty spreadsheet.
02
The score lands the same day
Online, by self-assessment link or in interview. Theme by theme, comparable over time.
03
The gap becomes a costed plan
Every step up carries its action. The AI prioritises on expected effect, not on the order of the standard.
04
Progress can be demonstrated
Campaign after campaign, against your target and against your own past. That is what your board asks for.
The maturity scale
One level, the next, and the action that links the two.
This mechanism (a level, a higher level, and the action linking the two) is what turns a finding into a trajectory.
Are the risk policies set by the lead entity transposed and applied in each subsidiary?
- N1
No group policy body exists. Each subsidiary applies its own locally defined rules.
- N2
Group policies exist and have been circulated, but local transposition is neither formalised nor checked. Gaps are known and tolerated.
- N3
Each subsidiary has a local variant approved by its deliberative body, and gaps are subject to a reasoned exception recorded at group level.
- N4
Application is periodically checked by group permanent control, exceptions are reviewed on schedule and uncovered gaps trigger a monitored action plan.
- N5
The policy body is revised in line with regulatory developments in host jurisdictions and lessons from control missions, with a documented history of revisions and their effects.
Action to move from level 2 to level 3
Open a register of transpositions and exceptions maintained by the group risk department, require each subsidiary to have its local variant approved by its board at the next sitting, and add the register review to the quarterly group risk committee agenda.
« With Datamensio, we meet our objectives far more efficiently. The ERDF inspection services and our supervising ministry particularly appreciated an approach that gives them reliable data. »
Director, CCI 94CCI Île-de-France
« We believe this is the most suitable solution to scale our transformation project and measure impact according to our needs. »
Maja SucekChief Operating Officer, Interreg Danube
Rarely on its own
Frameworks combine. Put several together to cover your business, or have the AI write yours.
Take your first measurementon BCEAO.
What this framework covers
Consolidated supervision organises the prudential oversight of a WAMU banking group at the level of the lead entity, not entity by entity. The lead institution or financial holding company must define the consolidation perimeter, exercise effective direction over its subsidiaries and branches, including outside the WAEMU zone, apply a consistent risk policy, produce consolidated prudential statements and comply with ratios on a consolidated basis. The WAMU Banking Commission licenses financial holding companies and assesses the lead entity’s ability to take on this responsibility.
In practice, the difficulty is rarely documentary, it is organisational. Does the consolidation perimeter truly cover all entities, including insurance, microfinance and card payment subsidiaries and significant minority holdings? Are group policies transposed in each jurisdiction, or do divergent local versions exist by tolerance? Do subsidiary control functions report to the parent company through a formalised functional line, or only during annual committees? Are prudential data submissions reconciled before transmission?
The regional context sharpens these questions. West African banking groups have expanded beyond WAEMU, into CEMAC, Guinea, Nigeria or the Maghreb, multiplying regulators, accounting frameworks and reporting time zones. The gradual transposition of Basel standards into the Union’s prudential framework has also raised expectations on the quality of consolidated capital and on large exposures assessed at group level. A frequent confusion remains: accounting consolidation is not consolidated supervision, the former aggregates accounts, the latter assumes effective steering.
A compliance audit ends with a binary finding: the requirement is met or it is not. A maturity assessment answers a different question. What level of control applies to effective group direction, the risk functional line, data submission. And what specific action moves from the observed level to the next one. This distinction changes the nature of the dialogue with the regulator as much as with subsidiary boards.
The framework is ready to use in Datamensio and adapts to your organisation. The AI adjusts the themes, questions and levels to the group’s actual perimeter, or builds a variant from your own documents: group governance charter, risk policy, consolidation procedures. Each subsidiary can be assessed separately, then compared against other business units.
Reference standard: BCEAO Instruction on the consolidated supervision of banking groups (WAEMU), read alongside the WAMU banking law and the Basel II/III WAEMU prudential framework
The themes assessed
Consolidation perimeter and group structure
Identification of included entities, treatment of significant holdings and non-banking entities, up-to-date capital structure chart, perimeter review during growth transactions.
Effective direction and governance bodies
Role of the lead entity’s deliberative body, composition and functioning of specialised committees, fitness and propriety of executives, coordination with subsidiary boards.
Group policies and standards
Common body of standards, local transposition procedure, exception management, adaptation to host jurisdiction requirements.
Consolidated risk management framework
Risk appetite defined at group level and cascaded down, risk functional line, aggregation of exposures, identification of cross-border concentrations.
Internal control and functional lines
Reporting lines for compliance, permanent control and internal audit functions, group audit plan, subsidiary coverage, follow-up of recommendations through to closure.
Capital and ratios on a consolidated basis
Determination of consolidated capital, calculation of the solvency ratio and large exposures at group level, capital allocation to entities, management of deductions.
Intragroup transactions and conflicts of interest
Register of intragroup transactions, market conditions, internal financing and guarantees, internal caps, reporting to the deliberative body.
Prudential reporting and information systems
Subsidiary data collection chain, reconciliation with accounting records, submission timetable, data quality and traceability, automated controls.
Relations with supervisory authorities
Single point of contact, exchanges with host supervisors, supervisory colleges, transmission of requested information, follow-up of directives and mission outcomes.
Continuity, recovery and group crisis management
Recovery plan at consolidated level, stress scenarios, continuity arrangements coordinated across entities, testing and lessons learned.
A short version of the framework is available for the online self-assessment.
Frequently asked questions
Does this assessment count as validation by the WAMU Banking Commission?
No. Datamensio measures the framework’s maturity and prepares for the prudential review, it does not issue any certification. Only the supervisory authority rules on compliance with requirements. The assessment serves to identify gaps before they are flagged during a mission.
What is the difference between this assessment and a regulatory compliance audit?
An audit checks whether a requirement is present and concludes with a gap or a compliance finding. The assessment places practice on a progressive scale and indicates the action that moves it up a level. The two complement each other: the assessment prepares and prioritises, the audit validates.
Can each subsidiary be assessed separately?
Yes. Each entity is a business unit assessed against the same framework. Scores can be compared across subsidiaries and over time, and a cross-cutting roadmap consolidates action plans from several assessments without duplicating shared actions.
How long does the assessment take?
Self-assessment is completed in one working session. In collaborative mode, with risk, compliance, finance and IT departments across several entities, data collection typically spans one to two weeks. Most of the time goes into gathering supporting evidence.
Is the framework adaptable to our group structure?
Yes. You can change the questions, levels and themes, or add ones that match your non-banking activities. The AI generates a variant from your governance charter and internal procedures, and refines the levels using the CMMI method.
How does this framework relate to subsidiaries outside WAEMU?
The questions address the group’s steering mechanisms, which apply regardless of the subsidiary’s jurisdiction. Local requirements from host supervisors can be added as a supplementary theme to cover the relevant entities.
Where is the data hosted?
In France, with OVH, with backup at Scaleway. No transfer outside the European Union. The AI models used can be selected, including from European providers.