Impact of IndAS on Banking Sector Dr Naveen J Sirohi School of Finance, IICA Impact of IndAS on Banking Sector

Background 2014 Budget Speech by FM Need for Integration with global Financial Reporting Standards MCA timeline Corporate (other than banks) starting April 1, 2016 Banks starting April 1, 2018 Banking Industry Heavily regulated Supersession of RBI over ICAI guidelines

Roadmap for IndAS Implementation in Banks RBI Circular RBI/2015-16/315 requires scheduled commercial banks to comply IFRS converged Indian Accounting Standards (IndAS) Mandatory for accounting period beginning April 01, 2018 Comparative Information for the period ending March 31, 2018 Applicable for both standalone & consolidated financial statements No earlier adoption permitted Reiterates timeline issued by MCA press release dated Jan 18, 2016 Holding companies, RRBs, Foreign offices etc all have to be IndAS compliant

Working Group Set up by RBI for IndAS Implementation Sen Committee Report dated Sept 8, 2015 giving recommendations into the following key areas with a focus on financial instruments: - Classification & Measurement of Financial Assets - Classification & Measurement of Financial Libilities - Hedge Accounting and Derivatives - Fair Value Measurement - Impairment of Financial Assets - Presentation of Financial Statements & Disclosures - Derocognition, Consolidation and other Residuary Issues Working Group also devised formats for financial statements of banks under IndAS and application guidance thereon

Activities & Reporting Requirement as per RBI Mandate Set up Steering Committee headed by official ED rank official Comprising members from cross-functional areas of banks to initiate the implementation process Inform RBI name and details of designated official and the team Audit committee to oversee progress & report to Board quarterly Disclose in the Annual Report the strategy for IndAS implementation including the progress made in this regard starting FY 2016-17 till implementation Boards of the Banks shall have the ultimate responsibility in determining the IndAS direction and strategy and in overseeing the development and execution on the IndAS implementation plan

Timeline FY 2016-17 Proforma Balance Sheet by September 2016 Preparatory Step FY 2017-18 Parallel Run of both systems Opening IndAS Balance Sheet Crucial FY 2018-19 IndAS system

Steps Step 1 Implementation Team Step 2 Capacity Building Top Management Team & Execution Team Step 2 Capacity Building Not just an accounting exercise | Integrated approach Step 3 Impact Study Item by item analysis | Different for different banks Step 4 Opening Balance Sheet (ending March 31, 2018) Most difficult part | Lot of data required | Role of IT Step 5 Final Statements (starting April 01, 2018) Depends on 4 steps | Long & tough journey, but important

Impact Financial Fair Valuation Increased loan loss provisioning (Example) Consequent impact on capital Human Resource Alignment of right resources Capacity building IT Systems Reliable data and credit models Change in MIS due to change in Reporting Stakeholders Expectation

Ground Reality Possibility of delayed Implementation as banks are finding it difficult to meet Basel III capital requirements by end March 2019 estimated around $90 billion Migration of IndAS 109 will require banks to switch to recognising and providing for Expected Credit Loss on financial assets rather than current practice of providing only when losses are incurred. It will lead to greater provisioning and earlier recognition of credit losses that will require additional capital (in addition to Basel III requirements) Operational challenges – Banks will need more data on how portfolios perform through the credit cycle and complex models of expected losses. Banks with sophisticated systems where there is robust data would have smooth journey.

Email: prof.sirohi@gmail.com Thank You.  Dr Naveen J Sirohi Email: prof.sirohi@gmail.com