Australian bankers are concerned about tight implementation timelines for APS 117, given the significant model development and testing work needed.
In July, the Australian Prudential Regulation Authority (APRA) finalised a revised standard on interest rate risk in the banking book (IRRBB), known as APS 117, as part of efforts to bolster the banking sector’s resilience and address potential vulnerabilities revealed by the 2023 bank runs.
APRA’s response to the 2023 banking sector turmoil in the US has focused on IRRBB, liquidity risk, and AT1 capital instruments, introducing changes that will challenge both large and small authorised deposit-taking institutions (ADIs).
The changes to APS 117 aim to reduce volatility in the IRRBB capital charge, create better incentives for banks to manage IRRBB, simplify the IRRBB framework, and make it more broadly applicable to the banking industry. The revised standard comes into effect on 1 October 2025.
In light of the upcoming changes, Regulation Asia and Wolters Kluwer hosted a private roundtable in Sydney at the end of September to understand the current status of implementation and the challenges being experienced in the industry.
Nearly 20 practitioners from banks, credit unions and mutual banks participated in the closed-door discussion. In this article, we summarise the findings.
Tight timelines
There are several milestones for ADIs leading up to the 1 October 2025 effective date for the revised APS 117. They will have to validate their IRRBB models by March 2025, ahead of two parallel runs that will take place for the reporting periods ending 30 June 2025 and 30 September 2024. For the parallel runs, ADIs must submit data through both the existing Direct to APRA (D2A) system and the new APRA Connect platform.
The roundtable participants expressed concerns that the timelines are too tight, particularly for advanced ADIs with significant model development work to do. One participant noted that there was a “long holding period” between the initial consultation in September 2019 and the finalisation of the revised APS 117 in July 2024, resulting in short timelines for implementation work, including model changes.
“The timelines are definitely tight, and some of the changes look to be fairly substantial, but actually, even the smaller changes require a lot of model development work and testing,” he said. “We are in our model build process and trying to adhere to the end-March 2025 timelines for advanced banks to have models developed and validated.”
The participant said the March 2025 model validation timeline also appears uncertain because APRA has scheduled on-site visits with advanced banks to “walk through” their models. “So it’s not fully clear whether APRA wants us to have model development and validation done by February instead,” he said.
One participant from a large bank said his institution had finished 90 percent of its model development work for APS 117 and that the next step is to start UAT testing. He said there is regulatory scrutiny on model development, but APRA will ultimately have to rely on the bank’s internal processes.
“Even if APRA had one person full-time for six months, they couldn’t go through all of our models with a fine tooth comb,” he said. “I feel like they’re going to be more checking to see if our validation and audit have done their job to validate our models.”
Another participant agreed, saying APRA appears to be focused on model governance rather than the models themselves. He added that this is likely because “this is the first time in a long time” that APRA will have a large number of models being submitted “almost simultaneously” for accreditation or re-accreditation.
Punitive elements
Some participants described elements of APS 117 as “punitive”, specifically pointing to areas like credit spread risk in the banking book (CSRBB) and the treatment of the earnings offset. “There are a few aspects of APS 117 that are pretty conservative when it comes to your overall risk-weighted asset requirement,” one participant said.
“We started a little bit later in the process because we were hopeful that APRA would be more receptive to some of the feedback from the industry on some of these aspects. The industry as a whole thought the feedback would be considered in the final revision to the standard, but to a large extent, they weren’t really.”
During the roundtable session, some participants complained that APRA rushed the finalisation of APS 117 because of fears that arose from the 2023 problems at US banks. As a result of these fears, APRA did not want to postpone application of the standard, they said.
The implications of APS 117 are seen as less significant for non-SFIs, though they will still face challenges from requirements to have risk frameworks in place to manage IRRBB, given that the new standard labels it as a “material risk”. This means smaller and less complex ADIs will be required to adhere to the same governance processes for managing IRRBB under CPS 220, APRA’s prudential standard for risk management.
According to participants from credit unions and mutual banks, these non-SFIs will have to put in place more advanced stress testing and modelling capabilities and enhanced governance around their risk management practices, which presents a challenge.
Not a global standard
A participant from a foreign bank in Australia noted a major challenge with APS 117: it’s not aligned with global standards. “What APRA is doing is problematic because, typically, there’s a global standard that allows us to examine approaches from other regulators, creating a degree of convergence,” he said.
“This feels like a one-size-fits-all, APRA-specific standard. Ideally, it should be less prescriptive and account for differences in banks’ maturity and size. Instead, APRA landed on a middle-of-the-road approach that doesn’t really work for large or small banks.”
One participant from a European bank echoed these concerns, explaining that APS 117 is “completely foreign and unfamiliar” to many of his bank’s group functions. The Australian unit collaborates closely with these global functions on financial risk, model validation, and model development, but the fundamental differences between APS 117 and European IRRBB regulations make this challenging, he said.
According to several participants, the European IRRBB framework, unlike APRA’s, adopts a proportionality principle, allowing banks to choose a more standardised approach based on their size and complexity. “The [European] framework primarily applies stress shocks to existing portfolios. For banks with liquidity and capital stress testing processes already in place, this makes the European IRRBB standards much simpler to implement.”
Migration to APRA Connect
APS 117 will require ADIs, including non-SFIs, to migrate from the existing D2A system to APRA Connect, which involves “table-based reporting instead of the current form-based reporting”, noted one participant from a credit union.
He said this would require “some additional work” to implement and that “this is just the beginning of a bigger transition of all reporting from D2A to APRA Connect over the next two years. Essentially, APRA will move everything into table-based reports, changing how reporting is done today.”
Another participant described the transition to APRA Connect as a “horrible experience” without elaborating further.
Another, who previously worked in the superannuation industry where APRA Connect is already broadly in use, said much more capacity will need to be added to the system to ensure it can ingest the large volumes of data expected from banks.
One participant suggested that banks will likely try to upload APS 117 data on the last day before the deadline at “exactly the same time”, questioning whether APRA is prepared to handle the large volumes of data at once.
He noted that European regulators have addressed similar capacity issues by spreading out the reporting dates for different types of reports.
Data governance
One of the key areas of discussion was data governance, specifically the need for ADIs to be able to use the same data sets for different internal functions, such as modelling the various risk types and other regulatory reporting.
Currently, most banks use different source data for many of these functions rather than having their data sets consistent across different departments. One roundtable participant described this as “the biggest challenge” for banks, as it can lead to errors and omissions of data in certain functions, including reporting.
“One of our key priorities is to make sure we’re using consistent data sets across the organisation for all financial risk metrics, including interest rate risk, liquidity, credit, and other risk types,” another participant said.
Some banks are trying to ease the burden of APS 117 reporting by looking for alignment of definitions with the existing EFS reporting requirements so that alignment can also be achieved in data-related and operational functions.
One of the participants noted, however, that many permutations of the same variables can be used in internal functions, making it more difficult to achieve such alignment. “What you find is, in a lot of cases, you’re generating the data just to comply with the regulatory obligation, and it doesn’t help you with your business operations,” he said.
Some participants expressed concerns that as the APRA Connect is further developed, the regulator will start to request even more data, such as extensive data around credit risk.