Entity tier model¶
The platform serves deposit takers of materially different sizes and regulatory complexity. The entity tier model is the mechanism by which the platform's obligation scope, calculation methodology, and governance portal views are configured per client without duplicating the underlying codebase.
Why tiers matter¶
Regulators in both NZ and AU operate explicit proportionality frameworks — smaller deposit takers have a different set of obligations, not merely a lighter set. The differences are qualitative:
- NZ Group 3 entities do not file IRRBB returns and are not subject to the OBR Standard. They are not just filing simpler versions — those obligations do not apply to them.
- AU Non-SFI entities use MLH (Minimum Liquidity Holdings) rather than LCR/NSFR — a different liquidity framework with different data inputs and a different calculation methodology.
- IRB capital accreditation is available only to NZ-G1 and APRA-approved AU entities (MSFI and some SFIs) — all others use Standardised.
A compliance traceability report produced for a NZ Group 3 credit union that includes OBR and IRRBB obligations is incorrect — those entries should not appear. The tier model ensures they do not.
NZ — DTA Proportionality Groups¶
Under the Deposit Takers Act 2023, the RBNZ has established four proportionality groups. The DTA takes full effect December 2028; standards are being progressively introduced from 2026.
| Group | Asset threshold | Representative entities |
|---|---|---|
| NZ-G1 | ≥ NZD 100 bn | The four major banks (D-SIBs) |
| NZ-G2 | NZD 2 – 100 bn | Mid-size banks |
| NZ-G3 | < NZD 2 bn | Credit unions, building societies, former NBDTs |
| NZ-G4 | N/A | Overseas branches incorporated elsewhere |
NZ-G3 is the primary target customer tier for this platform. Credit unions and building societies operating in NZ will fall here once the DTA is fully operative.
NZ non-core standards¶
The DTA Proportionality Framework designates certain standards as "non-core" and exempts NZ-G3 from them. NZ-G3 entities are not subject to:
- IRRBB Standard (nz-dta-irrbb)
- OBR Standard (nz-dta-obr)
- Outsourcing Standard (nz-dta-outsourcing)
- Operational Resilience Standard (nz-dta-operational-resilience)
- Lending Standard (nz-dta-lending)
These regulations carry entity_tiers: [NZ-G1, NZ-G2] in their YAML, ensuring they are
excluded from obligation traceability for NZ-G3 clients.
NZ-G4 (overseas branches) uses home-country prudential standards; NZ standards apply only in
limited ways (primarily AML/CFT). Branches carry entity_tiers: [NZ-G4] only on the NZ
branch-specific regulation.
AU — APRA ADI categories¶
APRA operates a current two-category framework transitioning to a three-tier framework expected to be finalised by end 2026.
| Tier | Status | Asset threshold | Representative entities |
|---|---|---|---|
| AU-MSFI | Proposed | ≥ AUD 300 bn | Four major banks + Macquarie |
| AU-SFI | Current | ≥ AUD 20 bn | Regional banks, large mutuals |
| AU-SFI-3T | Proposed | ≥ AUD 30 bn | Regional banks in three-tier framework |
| AU-NonSFI | Current | < AUD 20 bn | Credit unions, building societies, smaller mutuals |
| AU-NonSFI-3T | Proposed | < AUD 30 bn | Credit unions, building societies in three-tier framework |
The current and proposed frameworks must be supported simultaneously. Existing banks are demonstrating compliance readiness against both the operative standard and the proposed standard in parallel. The platform must produce a compliance report that covers both — see dual-standard support below.
The entity_tiers field¶
entity_tiers is a list[str] field on RegulationSpec, PolicySpec, and ModuleSpec.
Semantics:
- Empty list (default): The item applies to all tiers in the declared jurisdiction. This is the correct default for the vast majority of obligations — AML/CFT, privacy, payments, conduct, credit, and governance obligations apply universally.
- Populated list: The item applies only to the listed tiers. This is used for obligations where a proportionality exemption explicitly removes the obligation for smaller deposit takers.
What entity_tiers is not:
- It is not a severity or importance filter. OBR simply does not apply to Group 3 — it is not a "less important" OBR. The obligation is absent.
- It is not a disclosure filter within an obligation. Where an obligation applies to a tier but at reduced scale (e.g., simplified stress testing for Non-SFI), the obligation still appears; the module implementing it handles proportionality internally.
Dual-standard support¶
AU proposed tiers (AU-MSFI, AU-SFI-3T, AU-NonSFI-3T) co-exist with their current counterparts. A regulation or policy tagged for AU-SFI must also be tagged for AU-SFI-3T if it continues to apply under the proposed framework.
A compliance report for an AU SFI-level entity references: - AU-SFI obligations (current framework, operative today) - AU-SFI-3T obligations (proposed framework, planning horizon)
Both appear simultaneously. The status: Proposed flag on the tier profile is informational —
it does not exclude proposed-tier obligations from the report; it labels them.
Platform gaps¶
Two simplified liquidity calculation modes are not yet supported:
| Tier | Framework | Gap |
|---|---|---|
| NZ-G3 | CFCR (Core Funding Ratio) | MOD-032 calculates LCR/NSFR only. A CFCR calculation module is required for NZ-G3 deployments. |
| AU-NonSFI, AU-NonSFI-3T | MLH ≥ 9% | MOD-032 calculates LCR/NSFR only. A simplified MLH calculation module is required for AU Non-SFI deployments. |
Until these gaps are addressed, the platform cannot be deployed for NZ-G3 or AU-NonSFI entities
with full liquidity compliance. MOD-032 is tagged entity_tiers: [NZ-G1, NZ-G2, AU-SFI,
AU-MSFI, AU-SFI-3T] to reflect this accurately.
Runtime model¶
The tier dimension is a configuration attribute on the client entity record, not a code branch. The same deployed platform serves a G1 bank and a G3 credit union. The difference is in the obligation set rendered, the modules enabled, and the portal view presented.
A client entity record would carry:
- jurisdiction: NZ
- entity_tier: NZ-G3
The compliance report generator filters the obligation set to items where entity_tiers is
empty (universal) or contains NZ-G3. The portal suppresses modules tagged exclusively for
other tiers.
This model is consistent with the jurisdiction runtime model — both jurisdiction and tier are data attributes, not infrastructure boundaries.
Tier profiles¶
Full tier profiles (asset thresholds, capital and liquidity frameworks, D-SIB status, OBR applicability, disclosure tier, applicable non-core standards, and all tagged regulations, policies, and modules) are published at: