It is a well known and accepted fact in systems design that once the basic objectives of a system have been met, the cost of further expansion frequently outweighs any increased benefits and so effectively deters development. In many large organisations the implementation of sophisticated data base technology can represent both a profitable and necessary investment which, amongst other things, provides a comprehensive solution to the above problem. In other, perhaps small, installations the more important processing requirements are simply those of flexibility in file design and ease of changing formats. This paper sets out a proposal for a modified COBOL implementation which, by providing a level of data independence adequate to most DP installations, may be seen to offer a viable alternative to a full data-base system. The approach is based on the transferral of the data division file definitions, from the COBOL program, to the head of the physical files to which they pertain. Only those data elements referred to in the application logic need then be declared in the program itself, and association between the two definition sets may be deferred until run time. This work is an extension of that being currently undertaken by MacCallum (1973) and MacCallum and Jones (1975) forming part of a research programme aimed at improving information processing techniques.