Markdown Editor

Bank Stress Testing Programme Template (EBA/GL/2018/04)

Bank stress testing programme: governance, test inventory, scenario design, macro variables, methods by risk, results, actions, reverse stress test, use

Tài chính, Đầu tư & Kế toánĐầy đủEBA/GL/2018/04; CRD Arts 73, 86, 100; EBA/GL/2026/06; BCBS Stress testing principles 2018 (name only)stresstestingprogramme
Mở trong editorTải .md

Cách dùng: Use it to set up and document the annual stress testing framework of a credit institution that feeds the ICAAP, ILAAP, risk appetite and recovery plan. Fill the vulnerabilities, the test inventory and the scenario narratives first, and have the board discuss scenarios before any numbers are run. The main pitfall is a scenario that is severe for the economy but mild for the bank because it misses its own concentrations.

Xem trước

Stress Testing Programme: [Institution name] [Programme year, e.g. 2026 to 2027]

Stress testing programme for a credit institution: objectives and scope, governance, the inventory of stress tests, scenario design and severity calibration, the macro-financial variables, methodology by risk type, data and balance sheet assumptions, results, management actions, reverse stress testing, challenge and validation, and the use of results in the risk appetite framework, the ICAAP, the ILAAP and the recovery plan. Based on EBA Guidelines on institutions' stress testing (EBA/GL/2018/04), Directive 2013/36/EU (CRD) Articles 73, 86 and 100, and the revised EBA SREP and supervisory stress testing Guidelines (EBA/GL/2026/06, applying from 2027-01-01); structure also aligned with the Basel Committee "Stress testing principles" (October 2018), cited by name only. Requirements are referenced by number; obtain the guideline, directive or principles for the normative text and check the current version. Replace every [bracketed] value and every row marked Example. This is a document format, not financial, investment, legal, regulatory or accounting advice.

Document control

FieldValue
Document ID[STP-YYYY] Example: STP-2026
Institution and scope[Entities covered] Example: Fernhollow Bank, consolidated
Programme period[Dates] Example: 2026-07-01 to 2027-06-30
Reference date of the main run[YYYY-MM-DD] Example: 2026-12-31 (first run on 2026-09-30 data, rolled forward to the year-end balance sheet in January)
Scenario horizon[Years] Example: three years (2027 to 2029) for capital; 90 days and one year for liquidity
Currency and units[EUR million]
Version[0.1]
Status[Draft / In review / Approved]
Owner[@head-of-stress-testing]
Approvers/reviewers[@chief-risk-officer], [scenario committee], [risk committee], [management body]
Last updatedYYYY-MM-DD
Classification[Confidential]
Next review[YYYY-MM-DD]

Approvals

RoleNameDecisionDate
Head of stress testing (preparer)[@name][Submitted]YYYY-MM-DD
Chief economist (scenario owner)[@name][Scenario narrative confirmed]YYYY-MM-DD
Chief Risk Officer[@name][Recommend]YYYY-MM-DD
Board risk committee[@chair][Recommend to the management body]YYYY-MM-DD
Management body[@chair][Approve programme and scenarios]YYYY-MM-DD

Revision history

VersionDateAuthorChange summary
0.1YYYY-MM-DD[@name]Stress test inventory and calendar updated
0.5YYYY-MM-DD[@name]Example: SCN-002 narrative changed from recession to stagflation with CRE correction
1.0YYYY-MM-DD[@name]Example: Approved by the management body

Contents

1. Objectives and scope

State the objectives in terms of decisions: setting and testing the risk appetite, assessing capital and liquidity adequacy in the ICAAP and ILAAP, calibrating the recovery plan indicators, informing the strategic plan and the budget, setting limits and identifying concentrations and hidden vulnerabilities. Then state the scope: risk types, entities, portfolios, horizons and the frequency of each test.

Example: Fernhollow Bank's programme has five objectives: (1) confirm that capital stays above the risk appetite floor of 12.0% CET1 in a severe but plausible adverse scenario over three years, or define the actions that restore it; (2) confirm a liquidity survival horizon of at least 60 days in a combined liquidity stress; (3) test the commercial real estate concentration and the deposit franchise, the bank's two main vulnerabilities; (4) calibrate recovery plan indicators; and (5) support the annual strategic plan with a downside case. The scope covers all material risks in the ICAAP risk inventory and the consolidated perimeter. The small client-hedging trading book (internal model for general market risk) is stressed through the trading book scenarios and the stress loss limit MRL-003 (EUR 25 million) of the Market Risk Limit Framework (finance/market-risk-limit-framework); the result is immaterial at group level and is not modelled separately in SCN-002.

2. Governance and roles

Assign clear responsibilities across the three lines. The management body approves the programme and the main scenarios and discusses the results and actions; senior management runs the programme and ensures resources; the risk function owns methodology and coordination; finance owns the baseline projections; business lines provide expert input; model validation and internal audit provide independent challenge.

RoleResponsibilityOutput
Management body and risk committeeApprove programme, scenarios, results and actionsMinutes, approved scenarios
Scenario committee (CRO, CFO, chief economist, business heads)Design and challenge scenario narratives and severityScenario pack
Stress testing team (risk)Coordinate, run models, aggregate resultsResults pack
FinanceBaseline balance sheet and P&L projectionsBaseline plan
TreasuryLiquidity scenarios and funding responsesLiquidity results
Business linesExpert judgement on volumes, margins, client behaviourDocumented inputs
Model validationValidate satellite and stress modelsValidation reports
Internal auditReview the programme and its useAudit report

3. Stress test inventory

Cover the main types: sensitivity analysis (one risk factor moved at a time), scenario analysis (several factors moved together under a coherent narrative), reverse stress testing (starting from a defined failure point), and ad hoc tests requested by management or the supervisor. Include supervisory exercises in which the bank participates.

Test IDTypePurposeRisksFrequencyOwnerFeeds
ST-001 (Example)Scenario, enterprise-wideICAAP normative perspectiveAll materialAnnual, update half-yearlyStress testing teamICAAP, RAF
ST-002 (Example)Scenario, liquidityILAAP survival horizonLiquidity and fundingMonthly (full), weekly (light)Treasury and liquidity riskILAAP, CFP
ST-003 (Example)Sensitivity, creditCRE price shocks of 10%, 20% and 30%Credit, concentrationQuarterlyCredit riskSector limits
ST-004 (Example)Sensitivity, IRRBBSix supervisory interest rate shocks for EVE and NIIIRRBBQuarterlyALMIRRBB report
ST-005 (Example)Sensitivity, CSRBBSpread widening on liquidity portfolioCSRBBQuarterlyMarket riskICAAP
ST-006 (Example)Scenario, operationalSevere cyber event and external fraud waveOperationalAnnualORMICAAP, RCSA
ST-007 (Example)ReverseCapital and liquidity failure pointsAllAnnualStress testing teamRecovery plan
ST-008 (Example)Climate scenarioTransition and physical risk over a long horizonCredit, businessAnnualClimate riskStrategy, ICAAP

4. Scenario design

Start from the bank's vulnerabilities, write a narrative that explains how a shock unfolds and spreads, and then derive consistent paths for macro and market variables. Calibrate severity against history (for example the worst observed outcomes in comparable downturns), against supervisory scenarios and against expert views. Document why the scenario is plausible and why it is severe enough. Keep a baseline aligned with the budget so the stress effect can be read as a difference.

4.1 Scenario narratives

Scenario IDNameNarrative (Example)
SCN-001BaselineModerate growth, inflation close to 2%, stable policy rates; consistent with the strategic plan and budget
SCN-002Adverse: stagflation with CRE correctionAn energy supply shock pushes inflation back above 5%; central banks keep rates high, long rates rise by 150 bp, the economy contracts for two years, office and retail property values fall sharply as refinancing costs rise, SME defaults climb in energy-intensive sectors and depositors move savings to higher-yielding products
SCN-L01 to SCN-L03Liquidity scenariosIdiosyncratic, market-wide and combined liquidity shocks, defined in the ILAAP Report
SCN-004ReverseConstructed backwards from the MDA and TSCR breach points (section 9)

4.2 Macro-financial variables

Variable (Example)SCN-001 202720282029SCN-002 202720282029
Real GDP growth1.4%1.5%1.5%-2.5%-1.0%0.8%
Unemployment rate (annual average)6.1%6.0%5.9%7.8%9.0%8.6%
Consumer price inflation2.1%2.0%2.0%5.5%4.0%2.5%
Residential property prices (change)3.0%3.0%3.0%-7.0%-5.0%0.0%
Commercial property prices (change)1.0%2.0%2.0%-15.0%-10.0%-2.0%
10-year EUR swap rate (year end)2.6%2.7%2.8%4.1%3.9%3.5%
Equity index (change)5.0%5.0%5.0%-30.0%0.0%10.0%
BBB corporate spread change (bp)000+250+100-100

Cumulative property price changes in SCN-002: residential 0.93 x 0.95 x 1.00 = 0.8835, a fall of 11.7%; commercial 0.85 x 0.90 x 0.98 = 0.7497, a fall of 25.0%. The 10-year swap rate in SCN-002 is 150 bp above the baseline at the end of 2027 (4.1% minus 2.6%).

Translate the narrative into variables with a documented chain of reasoning: which variable moves first, how the others respond and why. Use the bank's own macroeconomic model or a recognised external forecast for the baseline, and apply shocks that are consistent with each other (for example, higher inflation with higher rates and weaker real income). Add bank-specific variables that the macro paths do not capture, such as deposit pricing pressure from competitors, the loss of a major client or a rating downgrade, and state how they interact with the macro shock. Keep every variable path in a scenario file with a version number so each model run can be traced to the scenario it used.

4.3 Severity calibration

Example: The scenario committee compared the GDP fall of SCN-002 (a cumulative decline of about 3.5% over two years, since 0.975 x 0.990 = 0.9653) with the deepest two-year contractions in the bank's markets since 2000 and with the most recent EU-wide adverse scenario, and judged it between the two. The commercial property fall of 25% is deliberately more severe than the residential fall because the bank's vulnerability lies there. The scenario is plausible because each element has occurred in the last 25 years, though not all together.

5. Methodology by risk type

For each risk type, describe the transmission from scenario variables to financial outcomes, the models or expert methods used, key parameters and limitations. Make the links between risks explicit, for example how higher rates raise both net interest income and credit losses, or how a rating downgrade affects both funding costs and deposit outflows.

RiskTransmission and method (Example)Model ID
Credit riskPD and LGD satellite models link default and loss rates to GDP, unemployment, rates and property prices; IFRS 9 stage migration and ECL recomputed each yearMOD-ST-03
ConcentrationDefault of the largest exposures tested separately; CRE LGD floored at 40%MOD-ST-03
IRRBB and NIIRepricing gap and deposit beta model under the scenario rate path; EVE under the scenario curveMOD-IR-02
CSRBB and valuationSpread shocks applied to FVOCI bonds; impact through other comprehensive income into CET1Market risk tools
Operational riskScenario-based losses (cyber event, fraud wave) added in year oneMOD-OR-04
Business riskFee income and volumes from business-line expert input, challenged by financeExpert
LiquidityBehavioural run-off and drawdown under each liquidity scenarioMOD-LQ-01, MOD-LQ-02
RWEACredit RWEA recomputed with stressed PDs for IRB portfolios and migration for standardised exposures; output floor testedCapital engine

Explain how the ECL under IFRS 9 is projected in stress (see ECL Methodology, finance/ecl-methodology) and how the results are kept consistent with accounting rules. Describe where expert judgement overrides model outputs and who approved it.

6. Data and balance sheet assumptions

Choose and justify the balance sheet assumption. A static balance sheet (maturing exposures replaced like for like) isolates the stress effect and supports comparison across years; a dynamic balance sheet reflects business plans and management reactions but must be credible under the scenario. Many banks run both. Record data sources, reconciliations with accounting and supervisory reports, and data limitations.

Example: Fernhollow Bank runs SCN-002 on a dynamic balance sheet for the ICAAP, with loan growth cut to zero in 2027 and to half the baseline rate in 2028 and 2029, and on a static balance sheet for the comparison with the supervisory exercise. Dividends are set to zero in the adverse scenario because the board's capital policy suspends distributions when the projected CET1 ratio falls below 13.5%.

Reconcile the starting point with the audited financial statements and the supervisory reports at the reference date, and record every manual adjustment in a data log with its approver. Where data are missing (for example historical loss data for a new product), use proxies from comparable portfolios or external data and add a conservative overlay. State the treatment of new business, prepayments, rating migration and collateral values, and keep the same assumptions across the capital and liquidity runs unless there is a documented reason to differ.

7. Results

7.1 Capital results (ST-001, SCN-002, before management actions)

Metric (Example)2026 actual202720282029Threshold
CET1 capital (EUR m)3,0002,7702,6202,720
TREA (EUR m)20,00021,40022,00021,800
CET1 ratio15.0%12.9%11.9%12.5%Floor 12.0%; OCR + P2G 10.125%
Leverage ratio6.8%6.2%5.9%6.0%3.0%
Cumulative impairments (EUR m)5201,0001,200

Main drivers of the 3.1 percentage point CET1 depletion to the 2028 trough: impairments of EUR 1,000 million over two years, of which commercial real estate EUR 430 million and SME lending EUR 390 million (the rest mortgages and consumer), valuation losses of EUR 130 million on the liquidity portfolio, operational losses of EUR 40 million, and RWEA inflation of EUR 2,000 million, mainly from rating migration and partly from the reduced loan growth in 2028, partly offset by pre-provision profit of EUR 680 million and tax effects of EUR 110 million. Check: 3,000 minus 1,000 minus 130 minus 40 + 680 + 110 = 2,620. Full details are in the ICAAP Report, section 8.

7.2 Liquidity results (ST-002)

Metric (Example)ResultAppetiteStatus
Survival horizon, combined stress SCN-L03about 80 days60 daysWithin appetite
LCR trough in SCN-002 (2028)124%120%Within appetite, below early warning 130%
NSFR trough in SCN-002 (2028)113%110%Within appetite, below early warning 115%

The liquidity results stay within appetite, but two of them fall below early warning levels in the adverse macro scenario. The programme therefore treats the 2028 senior bond maturity as the key liquidity vulnerability and links it to the pre-funding decision recorded in section 11. Read these results together with the capital results: the same scenario that lowers the CET1 ratio also slows deposit growth and raises funding costs, so capital and liquidity actions must be planned together.

7.3 Sensitivity results

TestShockImpact (Example)Limit or reference
ST-003CRE prices minus 30% (instantaneous)Additional ECL EUR 360 million, CET1 minus 1.6 pp after taxSector limit review trigger at minus 1.5 pp
ST-004Worst of six supervisory shocks (EVE)EVE minus EUR 300 million, 8.8% of Tier 1Outlier test threshold 15% of Tier 1
ST-005Spreads plus 200 bp on FVOCI bondsOCI minus EUR 95 millionInternal limit EUR 150 million

Recompute: 300 / 3,400 = 8.8% of Tier 1. A CET1 effect of 1.6 percentage points on TREA of 20,000 is EUR 320 million, which corresponds to an ECL increase of EUR 360 million less a tax effect of EUR 40 million (only part of the provision is tax deductible in the example).

8. Management actions

Define management actions in advance, linked to triggers in the risk appetite framework and recovery plan, and show results before and after them. Each action needs an owner, an estimated effect, a time to execute, preconditions and an assessment of feasibility under the specific scenario. Do not include actions that depend on market conditions the scenario has removed.

Action IDActionTriggerEffect in SCN-002 (Example)Feasibility
MA-001Suspend dividendsProjected CET1 below 13.5%Included in results (no distribution 2027 to 2029)High
MA-002Slow corporate lending growthProjected CET1 below 12.5%TREA minus EUR 300 millionHigh
MA-003Sell non-core participationProjected CET1 below 12.0%CET1 plus EUR 60 millionMedium
MA-004Synthetic securitisation of SME loansProjected CET1 below 11.5%TREA minus EUR 800 million (not counted)Medium, market dependent

With MA-002 and MA-003 the 2028 CET1 ratio becomes 2,680 / 21,700 = 12.35%, above the floor of 12.0%.

9. Reverse stress testing

Define failure points for capital (for example breach of the MDA threshold, breach of TSCR as a proxy for non-viability) and for liquidity (exhaustion of counterbalancing capacity). Work backwards to the loss or outflow that would cause each, then explore several combinations of events that could produce it, including non-macro events such as fraud, cyber attacks, conduct fines and the loss of a key counterparty. Assess plausibility and feed the results into early warning indicators and recovery options.

IDFailure pointRequired loss or outflow (Example)Plausible combinationsResponse
RST-001CET1 at OCR 9.125% (TREA 22,000)CET1 loss of EUR 992.5 million from 3,000SCN-002 plus a 40% CRE price fall and default of the two largest borrower groupsCRE limit cut, single-name limit review
RST-002CET1 at TSCR 5.625%CET1 loss of EUR 1,762.5 millionRST-001 plus a severe cyber event and forced asset sales after SME deposit flightRecovery indicators and options in finance/recovery-plan
RST-003Counterbalancing capacity exhausted within 30 daysNet outflows above EUR 8,500 million60% of SME and corporate deposits, 25% of less stable and 10% of stable retail deposits leave, no roll-over of wholesale funding maturing in the period, 15% of undrawn facilities drawn: net outflows 8,730 after inflows of 1,200 (ILAAP section 6.2)CFP early warning indicators in finance/contingency-funding-plan

Recompute: 3,000 minus (9.125% x 22,000 = 2,007.5) = 992.5; 3,000 minus (5.625% x 22,000 = 1,237.5) = 1,762.5. RST-003: 5,400 + 1,500 + 1,800 + 600 + 630 = 9,930 gross outflows; 9,930 minus 1,200 = 8,730, which exceeds the counterbalancing capacity of 8,500. The required outflow is about 1.8 times the 30-day net outflow of the combined scenario SCN-L03 (4,900), which is what makes the reverse scenario more extreme than the regular one.

10. Challenge, validation and audit

Document the challenge at each step: the scenario committee challenges narratives and variable paths; model validation reviews satellite models and overlays under the Model Risk Management Policy (finance/model-risk-management-policy) with findings recorded in Model Validation Reports (ai-data/model-validation-report); the risk committee challenges results and actions; internal audit reviews the whole programme periodically. Benchmark results against supervisory exercises and peer disclosures where available, and explain material differences.

Finding IDSourceFinding (Example)ActionDue
CH-001 (Example)Scenario committeeDeposit outflow assumption in SCN-002 too mild compared with 2023 bank failures abroadRaise less stable retail run-off by 5 points2026-11-30
CH-002 (Example)Model validationCRE LGD model not tested for price falls above 20%Floor CRE LGD at 40% pending re-estimation2027-03-31
CH-003 (Example)Internal auditExpert overlays on fee income not documentedOverlay log introduced2027-01-31

11. Use of results

Record the decisions taken on the basis of stress test results during the year, with dates and owners, so the supervisor and internal audit can see that stress testing is part of management and not a separate exercise.

DecisionBased onDate (Example)Owner
CRE sector limit lowered in steps from 14% to 12% of loans (13.5% end-2027, 12.5% end-2028, 12.0% end-2029)ST-001, ST-003, RST-0012026-12-15Credit committee
Risk appetite CET1 floor confirmed at 12.0%, with pre-approved actions MA-002 and MA-003ST-0012027-02-20Management body
Pre-funding of half of the 2028 senior bond maturityST-0022027-02-20ALCO
Recovery plan CET1 indicator set at 11.0%ST-001, RST-0012027-03-15Recovery plan owner

12. Annual calendar

Plan the cycle backwards from the date the ICAAP and ILAAP must be submitted. The management body should discuss and approve the scenario narratives before any numbers are produced, so that its challenge shapes the exercise rather than reacting to it. Leave time for at least one iteration between the first results and the final run, because the first results almost always reveal an assumption that needs to change. Run a lighter update at mid-year, or sooner if a trigger in the risk appetite framework fires or the economic outlook shifts materially, and record the reason for every off-cycle run in the stress test inventory.

Example: Fernhollow Bank approves scenarios at the end of August, produces first results in mid-November on 2026-09-30 data, challenges them in December, rolls them forward to the actual 2026-12-31 balance sheet in January and February, and signs the ICAAP and ILAAP in March. The roll-forward replaces the starting balance sheet and capital position with the year-end actuals and re-runs the projections; a material change from the first results goes back to the risk committee before sign-off.

13. Regulatory map and jurisdiction notes

TopicReferenceStatus as of 2026-10 (check the current version)
Institutions' own stress testingEBA/GL/2018/04, Guidelines on institutions' stress testingIn force; referenced by the revised SREP Guidelines
ICAAP and ILAAP stress testingCRD Arts 73 and 86In force
Supervisory stress testingCRD Art. 100; EBA/GL/2022/03 until 2026-12-31, EBA/GL/2026/06 from 2027-01-01EBA/GL/2026/06 repeals EBA/GL/2022/03 and EBA/GL/2017/05
EU-wide stress testEBA methodology for the relevant exercise (if the bank is in the sample)Check the EBA site for the current exercise
SSM expectationsECB Guide to the ICAAP (July 2026), Principle 7; ECB Guide to the ILAAP (November 2018), Principle 7Current
International principlesBasel Committee, Stress testing principles (October 2018)Name only
UK entity (if any)PRA supervisory statements on ICAAP (SS31/15, updated December 2025) and ILAAP (SS24/15)Names only; check the PRA Rulebook
US (if a US banking organisation exists)12 CFR part 252 company-run stress test requirements for covered companiesCheck thresholds and local law

14. Glossary and references

TermMeaning
Sensitivity analysisStress test that moves one risk factor or a small set of factors without a narrative
Scenario analysisStress test that moves many variables together under a coherent narrative
Reverse stress testTest that starts from a failure outcome and identifies scenarios that would cause it
Satellite modelModel linking scenario variables to risk parameters such as PD, LGD or deposit outflows
Static balance sheetAssumption that maturing positions are replaced like for like
Dynamic balance sheetAssumption that the balance sheet evolves with business plans and management reactions
Management actionPre-defined action that changes capital or liquidity, with trigger and feasibility assessment
OCR, TSCR, P2GOverall capital requirement, total SREP capital requirement, Pillar 2 guidance (see ICAAP Report)

References (cited by number and title; obtain the official text):

  • EBA, Guidelines on institutions' stress testing, EBA/GL/2018/04.
  • 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.
  • Directive 2013/36/EU (CRD), Articles 73, 86 and 100, as amended. EUR-Lex.
  • ECB, Guide to the ICAAP (July 2026) and Guide to the ILAAP (November 2018). ECB Banking Supervision.
  • Basel Committee on Banking Supervision, Stress testing principles, October 2018 (name only).

15. Standard and licence note

Based on EBA Guidelines EBA/GL/2018/04 and EBA/GL/2026/06, Directive 2013/36/EU (CRD) Articles 73, 86 and 100, and the ECB Guides to the ICAAP and ILAAP. Structure aligned with the Basel Committee "Stress testing principles" (October 2018), cited by name only. EUR-Lex, ECB and EBA material is reused with acknowledgement; guideline and article numbers are cited and no normative text is reproduced. The structure, guidance, scenarios and the Fernhollow Bank example are original; Fernhollow Bank and every figure are fictional. Check the current official versions before use. This is a document format, not financial, investment, legal, regulatory or accounting advice.

Template licence: MIT.

Template liên quan