ICAAP Report Template (Pillar 2, CRD Art. 73, ECB Guide)
Bank ICAAP report: capital adequacy statement, risk inventory, normative and economic perspectives, capital plan, adverse and reverse stress, buffers, actions
How to use: Use it for the annual Pillar 2 capital self-assessment of an EU credit institution, with the same reference date and scenarios as the ILAAP and stress testing programme. Fill the requirement stack (P1, P2R, buffers, P2G) and the risk inventory first, then project both perspectives. The main pitfall is a capital adequacy statement that restates ratios without a judgement, or an adverse scenario that misses the bank's own concentrations.
Preview
ICAAP Report: [Institution name] [Reference date, e.g. 2026-12-31]
Internal Capital Adequacy Assessment Process (ICAAP) report for a credit institution under Pillar 2: the capital adequacy statement, business model and strategy, risk identification, risk quantification under the normative and economic perspectives, the three-year capital plan, adverse scenarios and reverse stress testing, buffers, management actions, data and validation, and the board sign-off. Based on Directive 2013/36/EU (CRD) Article 73 as amended by Directive (EU) 2024/1619 (CRD6), Regulation (EU) No 575/2013 (CRR) as amended by Regulation (EU) 2024/1623 (CRR3, applying from 2025-01-01), the ECB Guide to the ICAAP (November 2018, revised July 2026), EBA Guidelines on ICAAP and ILAAP information collected for SREP purposes (EBA/GL/2016/10), and the revised EBA SREP Guidelines (EBA/GL/2026/06, applying from 2027-01-01). Requirements are referenced by article and guideline number; obtain the regulation, directive or guideline for the normative text and check the consolidated text. Replace every
[bracketed]value and every row marked Example. This is a document format, not financial, investment, legal, regulatory or accounting advice.
Document control
| Field | Value |
|---|---|
| Document ID | [ICAAP-YYYY] Example: ICAAP-2026 |
| Institution and scope | [Legal entity, consolidation level] Example: Fernhollow Bank, consolidated (prudential perimeter) |
| Reference date | [YYYY-MM-DD] Example: 2026-12-31 |
| Planning horizon | [Years] Example: 2027 to 2029 (three years) |
| Competent authority | [Supervisor] Example: ECB (SSM direct supervision through a Joint Supervisory Team; Fernhollow Bank is a significant institution) |
| Currency and units | [EUR million] |
| Linked ILAAP and stress test | [IDs] Example: ILAAP-2026, STP-2026 |
| Version | [0.1] |
| Status | [Draft / In review / Approved by the management body] |
| Owner | [@chief-risk-officer] |
| Approvers/reviewers | [@cfo], [risk committee], [management body] |
| Last updated | YYYY-MM-DD |
| Classification | [Confidential, supervisory] |
| Submission deadline | [YYYY-MM-DD as set by the supervisor] |
Approvals
| Role | Name | Decision | Date |
|---|---|---|---|
| ICAAP coordinator (preparer) | [@name] | [Submitted] | YYYY-MM-DD |
| Chief Risk Officer | [@name] | [Recommend] | YYYY-MM-DD |
| Chief Financial Officer | [@name] | [Recommend] | YYYY-MM-DD |
| Internal audit (review opinion) | [@name] | [Opinion issued, section 12] | YYYY-MM-DD |
| Board risk committee | [@chair] | [Recommend to the management body] | YYYY-MM-DD |
| Management body | [@chair] | [Approve and sign the capital adequacy statement] | YYYY-MM-DD |
Revision history
| Version | Date | Author | Change summary |
|---|---|---|---|
| 0.1 | YYYY-MM-DD | [@name] | Risk inventory and materiality assessment updated |
| 0.5 | YYYY-MM-DD | [@name] | Example: Capital plan and adverse scenario results added |
| 1.0 | YYYY-MM-DD | [@name] | Example: Approved by the management body; capital adequacy statement signed |
Contents
- Capital adequacy statement and executive summary
- Business model and strategy
- ICAAP governance
- Risk identification and materiality
- Capital position and requirements
- Economic perspective
- Normative perspective and capital plan
- Adverse scenarios and reverse stress test
- Management buffer and management actions
- Data, models and validation
- Regulatory map and jurisdiction notes
- Internal audit review and sign-off
- Glossary and references
- Standard and licence note
1. Capital adequacy statement and executive summary
1.1 Capital adequacy statement
Example: The management body of Fernhollow Bank has reviewed the ICAAP for the reference date 2026-12-31 and concludes that the bank's capital is adequate to cover its material risks and to carry out its strategy for 2027 to 2029. This conclusion rests on four findings. First, the CET1 ratio of 15.0% exceeds the overall CET1 requirement of 9.125% by 5.875 percentage points (EUR 1,175 million). Second, under the economic perspective internal capital of EUR 3,600 million covers the quantified risks of EUR 2,350 million by 153.2%, above the internal minimum of 120%. Third, the CET1 ratio stays above the overall capital requirement and the Pillar 2 guidance in every year of the adverse scenario, with a trough of 11.9% in 2028 before management actions and 12.35% after them. Fourth, the reverse stress test shows that only a combination of a deep commercial real estate crash and the default of the two largest borrower groups would bring the bank to its MDA threshold.
The management body accepts two vulnerabilities and has decided on actions: the adverse trough falls just below the risk appetite floor of 12.0% CET1, so the pre-approved management actions in section 9 are confirmed; and commercial real estate concentration is the largest driver of adverse losses, so the sector limit is lowered in steps from 14% to 12% of the loan book (13.5% at end-2027, 12.5% at end-2028, 12.0% at end-2029); on the plan assumptions the CRE share falls from 14.1% to 13.1%, 12.2% and 11.3% over the three years.
Signed for the management body: [Chair], [Chief Executive Officer], date YYYY-MM-DD.
1.2 Key figures
| Metric | 2026-12-31 actual | Requirement or appetite | Headroom |
|---|---|---|---|
| CET1 ratio (Example) | 15.0% | OCR 9.125%; OCR + P2G 10.125%; appetite floor 12.0% | 5.875 pp to OCR (EUR 1,175m) |
| Tier 1 ratio (Example) | 17.0% | 11.0% | 6.0 pp |
| Total capital ratio (Example) | 20.0% | 13.5% | 6.5 pp |
| Leverage ratio (Example) | 6.8% | 3.0% | 3.8 pp |
| Economic capital coverage (Example) | 153.2% | internal minimum 120% | EUR 780m above the minimum |
| Adverse CET1 trough (Example) | 11.9% (2028) | OCR + P2G 10.125% | 1.775 pp |
The coverage headroom is computed as internal capital minus 120% of quantified risk: 3,600 minus (1.2 x 2,350 = 2,820) = 780.
1.3 Changes since the previous ICAAP
Describe what changed in the business, the risk profile, the methodology, the supervisory requirements and the findings from the last SREP letter, and how each prior finding was closed.
| ID | Change or finding | Treatment in this ICAAP | Status |
|---|---|---|---|
| CHG-001 (Example) | CRR3 output floor phase-in factor rises from 55% in 2026 to 60% in 2027 | Floor tested in every plan year (section 5.3) | Closed |
| CHG-002 (Example) | Supervisory finding: CSRBB not quantified separately from IRRBB | Separate CSRBB measure added (section 6) | Closed |
| CHG-003 (Example) | ECB Guide to the ICAAP revised July 2026 (management buffer is the institution's own view) | Management buffer rationale rewritten (section 9.1) | Closed |
2. Business model and strategy
Describe the business model in terms the supervisor can test against the numbers: the customer segments, products, geographies, funding model and the main sources of income and of risk. Link every strategic initiative to its effect on risk-weighted exposure, earnings and capital, so the capital plan in section 7 can be traced back to the strategy.
Example: Fernhollow Bank is a retail and commercial bank with total assets of EUR 47,400 million, operating in two EU Member States. It lends to households (residential mortgages EUR 22,000 million) and to small and medium-sized enterprises and mid-corporates (EUR 15,000 million, including commercial real estate of EUR 5,200 million). It is funded mainly by retail and SME deposits (EUR 33,000 million) and senior preferred bonds (EUR 5,000 million). Net interest income is about 75% of revenue. The 2027 to 2029 strategy grows SME lending by 4% a year, keeps mortgage growth at 3% and reduces commercial real estate as a share of the book.
| Business line | Exposure (EUR m) | RWEA excl. operational risk (EUR m) | Share of revenue | Strategic direction |
|---|---|---|---|---|
| Retail mortgages (Example) | 22,000 | 4,400 | 35% | Grow 3% a year, keep LTV mix |
| SME and mid-corporate lending (Example) | 9,800 | 7,400 | 30% | Grow 4% a year |
| Commercial real estate (Example) | 5,200 | 4,200 | 12% | Reduce from 14.1% to below 12% of loans by end-2029 (CRE minus 5% a year) |
| Treasury, liquidity portfolio and trading book (Example) | 6,400 | 1,400 (credit 300, market 1,000, CVA 100) | 8% | Stable; trading book limited to client hedging |
| Payments and fees (Example) | n/a | 100 (other credit risk assets) | 15% | Grow fee income |
Check the sum: 4,400 + 7,400 + 4,200 + 1,400 + 100 = 17,500, which equals credit risk RWEA 16,400 (4,400 + 7,400 + 4,200 + 300 + 100) plus market risk 1,000 plus CVA 100 in section 5.1; operational risk RWEA of 2,500 is not allocated to business lines in this table. The leasing subsidiary's credit RWEA of 1,575 sits within SME and mid-corporate lending; the Risk Appetite Statement (finance/risk-appetite-statement, section 7) shows it separately and allocates operational risk by share of revenue.
3. ICAAP governance
Set out the roles, the committees, the annual calendar and the use of ICAAP results. The ECB Guide to the ICAAP expects the management body to take responsibility for a sound ICAAP and for the ICAAP to be integrated into the overall management framework (Principles 1 and 2); describe here how that is achieved in practice, not in general terms.
| Step | Owner | Challenge by | Output | Timing |
|---|---|---|---|---|
| Risk inventory and materiality | Risk control function | Risk committee | Risk map (section 4) | Q3 |
| Baseline plan | Finance | ALCO and executive committee | Three-year capital plan | Q3 to Q4 |
| Scenario design | Stress testing team | Scenario committee | Adverse and reverse scenarios | Q3 |
| Risk quantification | Risk measurement and model owners | Model validation | Economic capital by risk type | Q4 |
| Integration and conclusion | ICAAP coordinator | CRO, CFO | Draft report and CAS | Q4 |
| Independent review | Internal audit | Audit committee | Review opinion | Q1 |
| Approval | Management body | Supervisory function | Signed CAS | Q1 |
Use of the ICAAP: list each decision the results fed into during the year, for example the risk appetite limits, the capital allocation to business lines, the risk-adjusted pricing hurdle, the dividend recommendation and the recovery plan indicators. Record the board's challenge (questions raised, changes made) in the minutes and summarise it here.
4. Risk identification and materiality
Run the risk identification at least annually and whenever the business or the environment changes materially. Start from a broad taxonomy, assess each risk gross (before mitigation) and net, and apply a documented materiality threshold. Explain every risk judged immaterial so the supervisor can follow the reasoning.
| Risk ID | Risk type | Description | Materiality | Covered by Pillar 1 | ICAAP treatment |
|---|---|---|---|---|---|
| RSK-001 (Example) | Credit risk | Default and migration in mortgages and SME loans | Material | Yes (IRB mortgages, standardised elsewhere) | Economic capital model |
| RSK-002 (Example) | Concentration risk | Single-name and CRE sector concentration | Material | No | Add-on (Herfindahl-based and sector) |
| RSK-003 (Example) | IRRBB | Repricing and basis risk on non-maturity deposits | Material | No | EVE and NII under shocks; see finance/irrbb-policy-and-report |
| RSK-004 (Example) | CSRBB | Spread risk on the liquidity portfolio | Material | No | Spread shock on FVOCI and amortised cost bonds |
| RSK-005 (Example) | Operational risk incl. ICT and fraud | Process failure, cyber, external fraud | Material | Yes (CRR3 standardised approach) | Scenario-based economic capital |
| RSK-006 (Example) | Business and strategic risk | Margin compression, fee loss | Material | No | Earnings-at-risk model |
| RSK-007 (Example) | Market risk (trading book) | Small client-hedging book | Not material for economic capital (under 5% of quantified risk) | Yes (IMA for general market risk; standardised for specific risk) | Internal VaR and stressed VaR, floored at Pillar 1; see finance/var-backtesting-report |
| RSK-008 (Example) | Climate and environmental risk | Transition risk in CRE, physical risk in mortgages | Material as a driver | No | Driver of credit risk; scenario overlay |
| RSK-009 (Example) | Pension risk | Defined benefit scheme deficit | Not material | No | Qualitative, monitored |
| RSK-010 (Example) | Step-in risk | Support to a non-consolidated leasing entity | Not material | No | Qualitative, monitored |
Treat climate and environmental risks as drivers of existing risk types rather than as a separate bucket, and explain how they affect credit, operational and business risk over the horizon. Do the same for ICT and third-party risk, which usually sit inside operational risk.
5. Capital position and requirements
5.1 Own funds and risk-weighted exposure
| Item | EUR m (Example) |
|---|---|
| Common Equity Tier 1 (after deductions) | 3,000 |
| Additional Tier 1 | 400 |
| Tier 1 | 3,400 |
| Tier 2 | 600 |
| Total own funds | 4,000 |
| RWEA credit risk | 16,400 |
| RWEA market risk (IMA 962.5 plus standardised 37.5) | 1,000 |
| RWEA credit valuation adjustment | 100 |
| RWEA operational risk | 2,500 |
| Total risk exposure amount (TREA) | 20,000 |
| Leverage ratio exposure measure | 50,000 |
Check the TREA: 16,400 + 1,000 + 100 + 2,500 = 20,000. Market risk RWEA follows the current CRR internal model approach (CRR Articles 364 and 365) for general market risk and the standardised approach for specific risk, converted to RWEA at 12.5 times the own funds requirement (CRR Article 92(4)). Example: the 60-business-day average ten-day VaR is EUR 8.20 million and the 60-day average ten-day stressed VaR is EUR 13.80 million; with the multiplication factor of 3.50 that applies after the 2026-09-30 backtest (see the VaR Backtesting Report (finance/var-backtesting-report), section 7) and each multiplied average higher than the previous day's ten-day VaR and stressed VaR (CRR Article 364(1) takes the higher of the two), the IMA requirement is 3.50 x 8.20 + 3.50 x 13.80 = 28.70 + 48.30 = EUR 77.00 million. Standardised specific risk on the bond inventory adds EUR 3.00 million. Total market risk own funds EUR 80.00 million x 12.5 = RWEA 1,000 (IMA 962.5, standardised 37.5). Market risk is therefore 5% of TREA; keep this figure equal to the own funds return (COREP) at the reference date.
5.2 Requirement stack
The overall capital requirement combines the Pillar 1 minimum (CRR Article 92), the Pillar 2 requirement (CRD Article 104a) and the combined buffer requirement (CRD Articles 128 to 140, with distribution restrictions under Articles 141 and 142); Pillar 2 guidance (CRD Article 104b) sits above it and is not part of the MDA calculation (CRD Article 141).
| Layer | Basis | CET1 | Tier 1 | Total capital | CET1 EUR m |
|---|---|---|---|---|---|
| Pillar 1 minimum | CRR Art. 92 | 4.5% | 6.0% | 8.0% | 900 |
| Pillar 2 requirement (P2R 2.0%) (Example) | CRD Art. 104a | 1.125% | 1.5% | 2.0% | 225 |
| Total SREP capital requirement (TSCR) | 5.625% | 7.5% | 10.0% | 1,125 | |
| Capital conservation buffer | CRD Art. 129 | 2.5% | 2.5% | 2.5% | 500 |
| Countercyclical buffer (weighted) (Example) | CRD Art. 130 | 0.5% | 0.5% | 0.5% | 100 |
| O-SII buffer (Example) | CRD Art. 131 | 0.5% | 0.5% | 0.5% | 100 |
| Overall capital requirement (OCR), MDA threshold | CRD Art. 141 | 9.125% | 11.0% | 13.5% | 1,825 |
| Pillar 2 guidance (Example) | CRD Art. 104b | 1.0% | 1.0% | 1.0% | 200 |
| OCR plus P2G | 10.125% | 12.0% | 14.5% | 2,025 | |
| Risk appetite floor (Example) | Board RAS | 12.0% | 13.5% | 16.0% | 2,400 |
| Actual | 15.0% | 17.0% | 20.0% | 3,000 |
Check the arithmetic: CET1 share of P2R is 56.25% x 2.0% = 1.125%; Tier 1 share is 75% x 2.0% = 1.5%. The combined buffer is 2.5% + 0.5% + 0.5% = 3.5%. OCR for CET1 is 4.5% + 1.125% + 3.5% = 9.125%, which is EUR 1,825 million on TREA of EUR 20,000 million, so the MDA headroom is 3,000 minus 1,825 = EUR 1,175 million. The leverage ratio requirement is 3.0% under CRR Article 92(1)(d); Fernhollow Bank has no leverage ratio buffer because it is not a G-SII.
5.3 Output floor test (CRR3)
CRR3 introduced the output floor (CRR Article 92(3) and the transitional factors in Article 465). Banks using internal models compare TREA with a floor equal to a percentage of the TREA calculated using only standardised approaches. The transitional factor rises each year from 50% in 2025 (check the consolidated text of Article 465 for the current schedule and any transitional relief).
| Year | Floor factor (check Art. 465) | Standardised TREA (Example) | Floor amount | Modelled TREA | Binding? |
|---|---|---|---|---|---|
| 2026 | 55% | 23,500 | 12,925 | 20,000 | No |
| 2027 | 60% | 24,400 | 14,640 | 20,800 | No |
| 2028 | 65% | 25,300 | 16,445 | 21,600 | No |
| 2029 | 70% | 26,200 | 18,340 | 22,400 | No |
Recompute: 55% x 23,500 = 12,925; 60% x 24,400 = 14,640; 65% x 25,300 = 16,445; 70% x 26,200 = 18,340. The gap between standardised and modelled TREA (3,500 in 2026) comes mainly from the IRB mortgage book (standardised risk weights under CRR3 loan-splitting against IRB risk weights of about 20%) and the IMA for market risk. The floor is not binding in any plan year; the headroom narrows from 7,075 to 4,060, so re-test it each year and whenever an IRB model is recalibrated.
6. Economic perspective
Under the economic perspective, the institution assesses whether its internal capital covers the economic value effects of all material risks. Define internal capital (typically starting from CET1 and adjusting for items such as hidden losses on amortised cost assets, deferred tax and items with no loss-absorbing capacity in a going-concern view), the risk measure (for example value at risk or expected shortfall), the confidence level and the time horizon. Explain the choices; the guide does not prescribe a single method.
Example: Fernhollow Bank quantifies risks at a 99.9% confidence level over one year and takes no diversification benefit between risk types. Internal capital of EUR 3,600 million starts from CET1 of 3,000, adds Additional Tier 1 of 400 because it absorbs losses while the bank continues as a going concern, adds unrecognised fair value gains on the fixed-rate mortgage portfolio net of tax (EUR 320 million) and deducts unrealised losses on held-to-collect bonds net of tax (EUR 120 million): 3,000 + 400 + 320 minus 120 = 3,600. Tier 2 is excluded because it absorbs losses only when the bank is no longer viable, so the methodology treats it as a liability in this perspective.
| Risk ID | Risk type | Method | Economic capital EUR m (Example) | Pillar 1 comparison |
|---|---|---|---|---|
| RSK-001 | Credit risk | Portfolio model, 99.9%, one year | 1,300 | 1,312 (8% of RWEA 16,400) |
| RSK-002 | Concentration risk | Name and sector add-on | 150 | none |
| RSK-003 | IRRBB | Worst EVE outcome of six supervisory shocks plus basis | 300 | none |
| RSK-004 | CSRBB | Historical spread shock | 80 | none |
| RSK-005 | Operational risk | Scenario analysis plus loss distribution | 280 | 200 (8% of RWEA 2,500) |
| RSK-006 | Business and strategic risk | Earnings-at-risk | 120 | none |
| RSK-007 | Market risk (trading book) | Internal VaR and stressed VaR scaled to one year at 99.9%, floored at Pillar 1 | 90 | 80 (8% of RWEA 1,000) |
| RSK-009, RSK-010 | Pension and step-in | Qualitative buffer | 30 | none |
| Total, no diversification | 2,350 |
Check the sum: 1,300 + 150 + 300 + 80 + 280 + 120 + 90 + 30 = 2,350.
Explain every risk type where economic capital is below the Pillar 1 requirement, because the ECB Guide to the ICAAP expects the bank to justify it. Example: credit economic capital (1,300) is slightly below the Pillar 1 credit requirement (1,312) because the IRB mortgage PDs are point-in-time and the portfolio model recognises collateral more granularly than the regulatory formula; the difference is explained in the methodology annex and is never used to reduce the normative view, where Pillar 1 applies in full. Assess the economic perspective over time as well: project how internal capital and quantified risk evolve under the baseline and the adverse scenario, and explain how the results inform the normative perspective (for example, an IRRBB economic value loss that is not visible in regulatory ratios but will flow into future earnings).
7. Normative perspective and capital plan
The normative perspective is a multi-year view of the institution's ability to meet all regulatory and supervisory capital requirements and to keep its management buffer. The ECB Guide to the ICAAP expects a forward-looking horizon of at least three years. Use the approved budget and strategic plan for the baseline, include every known regulatory change and planned capital action, and reconcile with the economic perspective.
7.1 Baseline capital plan
| Item (EUR m) (Example) | 2026 actual | 2027 | 2028 | 2029 |
|---|---|---|---|---|
| Opening CET1 | 3,000 | 3,150 | 3,280 | |
| Net profit attributable | 260 | 270 | 280 | |
| Dividends (payout about 42% to 57%, within the 40% to 60% policy) | (110) | (140) | (160) | |
| Closing CET1 | 3,000 | 3,150 | 3,280 | 3,400 |
| TREA | 20,000 | 20,800 | 21,600 | 22,400 |
| CET1 ratio | 15.0% | 15.1% | 15.2% | 15.2% |
| Tier 1 ratio (AT1 400 constant) | 17.0% | 17.1% | 17.0% | 16.96% |
| Leverage exposure | 50,000 | 51,500 | 53,000 | 54,500 |
| Leverage ratio | 6.8% | 6.9% | 6.9% | 6.97% |
Payouts: 110 / 260 = 42.3%; 140 / 270 = 51.9%; 160 / 280 = 57.1%. Recompute every ratio: 3,150 / 20,800 = 15.14%; 3,280 / 21,600 = 15.19%; 3,400 / 22,400 = 15.18%. Tier 1: 3,550 / 20,800 = 17.07%; 3,680 / 21,600 = 17.04%; 3,800 / 22,400 = 16.96%. Leverage: 3,550 / 51,500 = 6.89%; 3,680 / 53,000 = 6.94%; 3,800 / 54,500 = 6.97%.
7.2 Key assumptions
| Assumption | Baseline (Example) | Source |
|---|---|---|
| Loan growth | Mortgages 3%, SME 4%, CRE minus 5% a year (net loan growth about 790 / 840 / 890; CRE share 13.1% / 12.2% / 11.3% at end-2027 / 2028 / 2029) | Strategic plan; ILAAP funding plan |
| Net interest margin | 1.55% falling to 1.45% as deposit rates catch up | ALCO forecast |
| Cost of risk | 25 bp of loans | ECL methodology (finance/ecl-methodology) |
| Dividend policy | 40% to 60% of net profit, subject to CET1 above 13.5% | Board capital policy |
| Capital issuance | Refinance AT1 at first call in 2028 like for like | Funding plan |
| Regulatory changes | Output floor factor per Art. 465; FRTB own funds requirements from 2027-01-01, subject to the 2026-06-04 delegated act; the IMA permission does not carry over, so the plan assumes the alternative standardised approach from 2027 within the TREA path shown (check the final rules) | Regulatory map, section 11 |
8. Adverse scenarios and reverse stress test
Design the adverse scenario in the Stress Testing Programme (finance/stress-testing-programme) and report its capital effects here. The scenario must be severe but plausible, cover the whole horizon, reflect the bank's specific vulnerabilities and capture interactions between risks. Show results before and after management actions, and compare them with every layer of the requirement stack.
8.1 Adverse scenario results (SCN-002, stagflation with CRE correction)
| Item (EUR m) (Example) | 2027 | 2028 | 2029 |
|---|---|---|---|
| Opening CET1 | 3,000 | 2,770 | 2,620 |
| Pre-provision profit | 380 | 300 | 340 |
| Impairments | (520) | (480) | (200) |
| Valuation losses (FVOCI, CSRBB) | (110) | (20) | 0 |
| Operational risk losses | (40) | 0 | 0 |
| Tax effect | 60 | 50 | (40) |
| Dividends | 0 | 0 | 0 |
| Closing CET1 | 2,770 | 2,620 | 2,720 |
| TREA | 21,400 | 22,000 | 21,800 |
| CET1 ratio | 12.9% | 11.9% | 12.5% |
| Leverage exposure | 51,000 | 51,000 | 52,000 |
| Leverage ratio (AT1 400 constant) | 6.2% | 5.9% | 6.0% |
Recompute: 3,000 + 380 minus 520 minus 110 minus 40 + 60 = 2,770; 2,770 + 300 minus 480 minus 20 + 50 = 2,620; 2,620 + 340 minus 200 minus 40 = 2,720. Ratios: 2,770 / 21,400 = 12.94%; 2,620 / 22,000 = 11.91%; 2,720 / 21,800 = 12.48%. Leverage: (2,770 + 400) / 51,000 = 6.22%; (2,620 + 400) / 51,000 = 5.92%; (2,720 + 400) / 52,000 = 6.0%. Cumulative impairments are 520 + 480 + 200 = EUR 1,200 million. The maximum CET1 depletion is 15.0% minus 11.9% = 3.1 percentage points. The 2028 trough remains 1.775 percentage points above OCR plus P2G (10.125%) and 2.775 points above the MDA threshold (9.125%), but 0.1 points below the risk appetite floor of 12.0%, which triggers the management actions in section 9.
8.2 Reverse stress test
The reverse stress test starts from an outcome and works backwards to the scenarios that would cause it. Define the outcomes (for example breach of the MDA threshold and breach of TSCR as a proxy for non-viability), find the loss size that causes each, and describe plausible combinations of events that would produce that loss.
| Outcome | CET1 threshold at TREA 22,000 | CET1 amount | Loss from 2026 CET1 of 3,000 | Scenario that reaches it (Example) |
|---|---|---|---|---|
| RST-001: breach of OCR (MDA) | 9.125% | 2,007.5 | 992.5 | SCN-002 plus a 40% CRE price fall and default of the two largest borrower groups |
| RST-002: breach of TSCR | 5.625% | 1,237.5 | 1,762.5 | RST-001 plus a severe cyber event and a 30% outflow of SME deposits forcing asset sales at a loss |
Recompute: 9.125% x 22,000 = 2,007.5 and 5.625% x 22,000 = 1,237.5. Conclude whether the scenarios are implausible enough to accept or whether they call for action; feed the results into the recovery plan indicators (finance/recovery-plan).
9. Management buffer and management actions
9.1 Management buffer
The management buffer is the institution's own view of the capital it needs above regulatory and supervisory minima to keep its business model sustainable; the July 2026 revision of the ECB Guide to the ICAAP makes clear it is not a supervisory requirement and is separate from Pillar 2 guidance. Explain how the buffer was calibrated, for example from the adverse scenario depletion, earnings volatility and the time needed to execute actions.
Example: Fernhollow Bank sets its CET1 management buffer at 1.875 percentage points above OCR plus P2G, giving the risk appetite floor of 12.0% (10.125% + 1.875% = 12.0%). The buffer is calibrated at about 60% of the 3.1 percentage point CET1 depletion in the adverse scenario (1.875 / 3.1 = 60.5%), because the board judges that the pre-approved actions in section 9.2 can restore part of any larger loss within the horizon. The actual CET1 ratio of 15.0% sits 3.0 points above the floor; the adverse depletion would take the bank 0.1 points below it, and MA-002 and MA-003 restore about 0.44 points (12.35% minus 11.91%).
9.2 Management actions
| Action ID | Action | Trigger | Capital effect (Example) | Time to execute | Feasibility in stress |
|---|---|---|---|---|---|
| MA-001 (Example) | Suspend dividend | CET1 below 13.5% projected | Already assumed in SCN-002 | Immediate | High |
| MA-002 (Example) | Slow corporate lending growth | CET1 below 12.5% projected | TREA minus 300 | Two quarters | High |
| MA-003 (Example) | Sell non-core participation | CET1 below 12.0% projected | CET1 plus 60 | Three quarters | Medium |
| MA-004 (Example) | Synthetic securitisation of SME loans | CET1 below 11.5% projected | TREA minus 800 | Two to three quarters | Medium, market dependent |
After MA-002 and MA-003 the 2028 adverse position becomes CET1 2,620 + 60 = 2,680 and TREA 22,000 minus 300 = 21,700, a ratio of 2,680 / 21,700 = 12.35%, back above the risk appetite floor. MA-004 is held in reserve and is not counted because it depends on investor appetite in a stress.
10. Data, models and validation
List every model and data set used in the ICAAP quantification and projections, with its owner, validation status and known limitations, and the overlay applied where a limitation is material. Model governance follows the Model Risk Management Policy (finance/model-risk-management-policy); validation results are recorded in Model Validation Reports (ai-data/model-validation-report).
| Model ID | Use in ICAAP | Owner | Last validation | Open findings | Overlay (Example) |
|---|---|---|---|---|---|
| MOD-CR-01 (Example) | Credit portfolio model (economic capital) | Credit risk modelling | 2026-06 | 1 medium (correlation calibration) | Plus 5% on credit economic capital |
| MOD-IR-02 (Example) | Non-maturity deposit model (IRRBB) | ALM | 2026-03 | None | None |
| MOD-ST-03 (Example) | Satellite PD and LGD models for stress | Stress testing team | 2025-11 | 1 high (CRE LGD sensitivity) | CRE LGD floored at 40% in SCN-002 |
| MOD-OR-04 (Example) | Operational risk scenario model | ORM | 2026-09 | None | None |
Describe data quality controls (reconciliation with accounting and COREP, completeness checks, manual adjustments with approval) and how the ICAAP data architecture meets the bank's risk data aggregation principles.
11. Regulatory map and jurisdiction notes
| Topic | Reference | Status as of 2026-10 (check the consolidated text) |
|---|---|---|
| ICAAP obligation | CRD Art. 73 (internal capital), Art. 74 (governance) | In force; CRD6 (Directive (EU) 2024/1619) amendments transposed by Member States from 2026-01-11 |
| Own funds requirements | CRR Art. 92; CRR3 (Regulation (EU) 2024/1623) | CRR3 applies from 2025-01-01; output floor phase-in under Art. 465 |
| Market risk (FRTB) | CRR3 market risk provisions | Own funds requirements postponed to 2027-01-01; a further Commission delegated act published 2026-06-04 with transitional amendments to end-2029 was under scrutiny by Parliament and Council (check status) |
| Pillar 2 | CRD Art. 104a (P2R), Art. 104b (P2G) | In force |
| Supervisory review | EBA/GL/2022/03 until 2026-12-31; EBA/GL/2026/06 from 2027-01-01 | EBA/GL/2026/06 repeals EBA/GL/2022/03 and EBA/GL/2017/05 |
| ICAAP information for SREP | EBA/GL/2016/10 | In force |
| Supervisory expectations (SSM) | ECB Guide to the ICAAP (July 2026) | Current version; replaces November 2018 version |
| UK (if a UK entity exists) | PRA SS31/15 (updated December 2025); PRA Basel 3.1 rules from 2027-01-01 | Names only; check the PRA Rulebook |
| US (if a US branch exists) | No ICAAP equivalent for branches; US Basel III endgame re-proposal of 2026-03-19 is a proposal | Check local law |
12. Internal audit review and sign-off
Internal audit reviews the ICAAP process at least periodically under the bank's audit plan: governance and use, completeness of risk identification, methodology and data quality, the integrity of the projections and the follow-up of supervisory findings. Summarise the scope, the opinion and the findings; attach the full report as an annex.
| Finding ID | Area | Finding (Example) | Rating | Action owner | Due date |
|---|---|---|---|---|---|
| IA-ICAAP-01 (Example) | Data | Manual adjustment to CRE collateral values not approved in the data log | Medium | [@head-credit-risk] | 2027-03-31 |
| IA-ICAAP-02 (Example) | Use | Capital allocation to business lines still uses the 2025 economic capital | Low | [@cfo] | 2027-06-30 |
Sign-off: confirm that the management body discussed the report, challenged the key assumptions and approved the capital adequacy statement in section 1.1. Record the date of the meeting and the minute reference.
13. Glossary and references
| Term | Meaning |
|---|---|
| CAS | Capital adequacy statement, the management body's signed conclusion on capital adequacy |
| CET1, AT1, T2 | Common Equity Tier 1, Additional Tier 1, Tier 2 capital |
| TREA, RWEA | Total risk exposure amount; risk-weighted exposure amount |
| P2R, P2G | Pillar 2 requirement (binding); Pillar 2 guidance (supervisory expectation) |
| TSCR, OCR | Total SREP capital requirement (P1 + P2R); overall capital requirement (TSCR + combined buffer) |
| MDA | Maximum distributable amount, the restriction on distributions when the combined buffer is not met |
| Normative perspective | Multi-year projection of regulatory capital ratios against requirements |
| Economic perspective | Comparison of internal capital with an internal economic measure of all material risks |
| IRRBB, CSRBB | Interest rate risk and credit spread risk in the banking book |
| Output floor | Lower bound on TREA set as a percentage of the standardised TREA (CRR3) |
References (cited by number and title; obtain the official text):
- Directive 2013/36/EU (CRD), Articles 73, 74, 104a, 104b, 128 to 142, as amended by Directive (EU) 2024/1619 (CRD6). EUR-Lex.
- Regulation (EU) No 575/2013 (CRR), Articles 92 and 465, as amended by Regulation (EU) 2024/1623 (CRR3). EUR-Lex.
- ECB, Guide to the internal capital adequacy assessment process (ICAAP), July 2026 (revision of the November 2018 guide). ECB Banking Supervision.
- EBA, Guidelines on ICAAP and ILAAP information collected for SREP purposes, EBA/GL/2016/10.
- EBA, Guidelines (revised) on common procedures and methodologies for SREP and supervisory stress testing, EBA/GL/2026/06, 26 June 2026, applying from 2027-01-01.
- EBA, Guidelines on institutions' stress testing, EBA/GL/2018/04.
- Basel Committee on Banking Supervision, Basel Framework, supervisory review process chapters (SRP) (name only).
14. Standard and licence note
Based on Directive 2013/36/EU (CRD) and Regulation (EU) No 575/2013 (CRR) as amended by CRD6 and CRR3, the ECB Guide to the ICAAP (July 2026) and EBA Guidelines EBA/GL/2016/10, EBA/GL/2018/04 and EBA/GL/2026/06. EUR-Lex, ECB and EBA material is reused with acknowledgement; article and guideline numbers are cited and no normative text is reproduced. Basel Committee material is cited by name only. The structure, guidance and the Fernhollow Bank example are original; Fernhollow Bank and every figure are fictional. Check the current official versions and the consolidated texts before use, as requirements and supervisory expectations change. This is a document format, not financial, investment, legal, regulatory or accounting advice.
Template licence: MIT.
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