| name | ifrs9-disclosure |
| description | Activate for: IFRS 7 disclosure, ECL disclosure note, credit risk disclosure, IFRS 9 annual report note, sensitivity analysis IFRS 9, stage distribution table, credit quality table, IFRS 7 note drafting. NOT for: ECL calculation methodology (use ifrs9-ecl), staging assessment (use ifrs9-staging), US GAAP disclosure requirements under ASC 326 / CECL.
|
| metadata | {"version":"1.0","author":"Panaversity — The AI Agent Factory","standard":"IFRS 7 Financial Instruments Disclosures"} |
IFRS 7 ECL DISCLOSURE REQUIREMENTS — COMPLETE LIST
Qualitative Disclosures (always required)
- SICR assessment methodology — quantitative and qualitative criteria used
- Definition of default — the bank's specific definition and why it was chosen
- Write-off policy — when exposures are derecognised (written off)
- Macroeconomic scenario descriptions — narrative for each scenario
- ECL model methodology — overview for each major portfolio segment
- PMA rationale — types and reasons for post-model adjustments
Quantitative Disclosures (always required)
- Stage distribution table — gross carrying amount and ECL by stage, by product
- Stage migration table — movements during the period with ECL impact
- Credit quality table — gross carrying amounts by internal credit grade
- Macroeconomic variables — key variables and their values in each scenario
- Scenario weights — probability assigned to each scenario
- Sensitivity analysis — ECL under each scenario individually (IFRS 7.35G)
- PMA amounts — aggregate PMA by direction (add/release) with rationale
- Modified financial assets — amounts restructured, conditions, Stage post-modification
- Collateral — types held, LTV distributions for mortgage portfolios
- Concentration risk — geographic and industry concentrations
For Stage 3 Specifically
- Gross carrying amount vs. ECL provision by product (coverage ratio)
- Write-offs during the period
- Recoveries on previously written-off amounts
TEMPLATE: STAGE DISTRIBUTION TABLE
| Stage 1 | Stage 2 | Stage 3 | Total |
|---|
| Gross carrying amount (M) | | | | |
| ECL provision (M) | | | | |
| Net carrying amount (M) | | | | |
| ECL coverage ratio % | | | | |
| Number of facilities | | | | |
Repeat for each major product category (mortgages, SME, corporate, consumer, etc.)
TEMPLATE: STAGE MIGRATION TABLE
| Movement | Gross Amount (M) | ECL Impact (M) |
|---|
| Opening balance — Stage 1 | | |
| Opening balance — Stage 2 | | |
| Opening balance — Stage 3 | | |
| New financial assets originated (all Stage 1) | + | + |
| Transfers: Stage 1 to Stage 2 | reclassify | + (lifetime vs. 12-mo ECL) |
| Transfers: Stage 1 to Stage 3 | reclassify | + |
| Transfers: Stage 2 to Stage 3 | reclassify | + |
| Transfers: Stage 3 to Stage 2 (cures) | reclassify | - |
| Transfers: Stage 2 to Stage 1 (cures) | reclassify | - |
| Repayments / maturities | - | - (ECL released) |
| Write-offs | - | - (matched derecognition) |
| Changes in model parameters | -- | +/- |
| Changes in macroeconomic scenarios | -- | +/- |
| PMA movements | -- | +/- |
| Closing balance — Stage 1 | | |
| Closing balance — Stage 2 | | |
| Closing balance — Stage 3 | | |
TEMPLATE: CREDIT QUALITY TABLE
| Internal Grade | Description | Gross Amount (M) | ECL (M) | Coverage % |
|---|
| 1 -- Minimal risk | AAA-AA equivalent | | | |
| 2 -- Low risk | A equivalent | | | |
| 3 -- Standard | BBB equivalent | | | |
| 4 -- Watch | BB equivalent, SICR approaching | | | |
| Stage 2 -- SICR | Various | | | |
| Stage 3 -- Default | Various | | | |
TEMPLATE: COLLATERAL AND LTV DISTRIBUTION TABLE (IFRS 7.35K)
| LTV Band | Gross Amount (M) | ECL (M) | Coverage % | % of Mortgage Book |
|---|
| <= 50% | | | | |
| 50-60% | | | | |
| 60-70% | | | | |
| 70-80% | | | | |
| 80-90% | | | | |
| 90-100% | | | | |
| > 100% (negative equity) | | | | |
| Total | | | | |
Collateral types to disclose: residential property, commercial property,
cash collateral, financial guarantees, credit insurance, receivables.
For each type: fair value, frequency of revaluation, methodology for valuation.
TEMPLATE: CONCENTRATION RISK TABLE (IFRS 7.35M)
| Dimension | Segment | Gross Amount (M) | % of Total | ECL (M) | Coverage % |
|---|
| Geography | UK | | | | |
| Geography | Europe (ex-UK) | | | | |
| Geography | North America | | | | |
| Geography | Asia Pacific | | | | |
| Geography | Middle East | | | | |
| Industry | Financial services | | | | |
| Industry | Real estate | | | | |
| Industry | Manufacturing | | | | |
| Industry | Retail/Consumer | | | | |
SENSITIVITY ANALYSIS FORMAT (IFRS 7.35G REQUIREMENT)
"If the [upside / adverse / severe] macroeconomic scenario were applied with a
100% weighting, the Group's ECL provision would be [X higher / X lower],
representing a [Y%] [increase / decrease] from the reported provision of [Z]."
Calculate and disclose for each named scenario.
This is one of the most scrutinised disclosures in bank annual reports.
Extended Sensitivity Disclosure (Best Practice)
In addition to single-scenario sensitivity, disclose:
- ECL impact of a 10% shift in scenario weights (e.g., 10% from base to severe)
- ECL impact of a 1pp increase in unemployment across all scenarios
- ECL impact of a 10% decline in HPI across all scenarios
These additional sensitivities help investors and analysts assess model responsiveness.
DRAFTING STANDARDS FOR ECL NOTES
- Use plain English alongside technical terms
- Quantify every disclosure where possible (avoid "significant" without a number)
- Cross-reference to the accounting policy note for IFRS 9 classification and measurement
- Distinguish clearly between performing (Stage 1/2) and non-performing (Stage 3)
- Auditors will check every number in the disclosure ties to the ECL model output
- Ensure year-on-year comparatives are presented for all quantitative tables
- Changes from prior period must be explained narratively, not just shown numerically
OUTPUT FORMAT — DISCLOSURE NOTE DRAFT
IFRS 7 ECL DISCLOSURE NOTE
Entity: [Bank / Group name]
Reporting Period: [YYYY-MM-DD to YYYY-MM-DD]
SECTION 1: QUALITATIVE
SICR methodology: [Summary of quantitative and qualitative criteria]
Definition of default: [Bank's definition with rationale]
Write-off policy: [When exposures are derecognised]
ECL model overview: [Summary by portfolio segment]
PMA rationale: [Types applied and reasons]
SECTION 2: QUANTITATIVE
[Stage distribution table — by product]
[Stage migration table — with ECL impact]
[Credit quality table — by rating grade]
[Sensitivity analysis — per IFRS 7.35G]
[Scenario weights and key variables]
[PMA aggregate amounts]
[Collateral / LTV distribution]
[Concentration risk — geographic and industry]
SECTION 3: STAGE 3 DETAIL
Stage 3 coverage ratios by product
Write-offs during period
Recoveries on prior write-offs
NEVER DO THESE
- NEVER draft disclosure tables from a stale risk system extract — all numbers must tie to the approved ECL model output for the reporting date; stale extracts are the most common source of disclosure restatements
- NEVER omit the IFRS 7.35G sensitivity analysis — regulators and auditors treat this as a mandatory disclosure; omission will result in a qualified audit opinion or regulatory finding
- NEVER present ECL disclosure without year-on-year comparatives — IFRS 7 requires comparative information, and omission raises immediate auditor concern
- NEVER use vague language ("significant increase", "material amount") without quantification — every qualitative descriptor must be supported by a number
- NEVER disclose scenario weights that do not sum to 100% — this is an immediate credibility issue and will be flagged by both auditors and analysts
ALL OUTPUTS REQUIRE REVIEW BY A QUALIFIED PROFESSIONAL BEFORE USE IN REGULATORY FILINGS OR BUSINESS DECISIONS.