AU ADI — Most Significant Financial Institution (proposed)¶
| Tier ID | AU-MSFI |
| Jurisdiction | AU |
| Status | Proposed — not yet operative |
| Asset threshold | > AUD 300 billion (proposed) |
| Effective from (est.) | 2027-12-31 |
| Capital methodology | IRB-eligible |
| Liquidity framework | LCR-NSFR |
| OBR applicable | No |
| Disclosure tier | Full |
| D-SIB eligible | Yes |
Proposed standard
This tier is defined under a proposed regulatory framework that is not yet operative. The platform must demonstrate compliance against both the current operative tier and this proposed tier simultaneously, as existing institutions are planning for the forthcoming standard now.
Notes
Proposed highest tier under APRA's three-tier proportionate banking framework (consultation paper December 2025; finalisation expected end 2026). Currently captures approximately 5 entities — ANZ, CBA, NAB, Westpac, and Macquarie Bank. Carries the most stringent requirements across all prudential standards. D-SIB LAC/TLAC requirements being finalised by APRA from January 2026. Enhanced FAR accountability notifications and fuller resolution planning obligations. The platform must demonstrate compliance against both the current SFI framework (AU-SFI) and this proposed MSFI standard simultaneously.
Profile¶
The Most Significant Financial Institution (MSFI) is the proposed highest tier in APRA's three-tier proportionate banking framework, consulted on in December 2025 with finalisation expected by end 2026. The AUD 300 billion threshold captures approximately five entities: ANZ Banking Group, Commonwealth Bank of Australia, National Australia Bank, Westpac Banking Corporation, and Macquarie Bank.
Status: Proposed — not yet operative. The platform must demonstrate compliance against both the current AU-SFI framework and this proposed MSFI standard simultaneously. Existing banks operating at this scale are actively preparing for the MSFI standard now.
Why model a proposed standard¶
Existing banks classified as current SFIs that will become MSFIs are required to demonstrate readiness for the forthcoming standard well ahead of the effective date. Regulators expect institutions to begin planning immediately upon consultation publication. This SaaS platform must therefore show that it can support MSFI-level obligations in order to be credible to larger prospects and to demonstrate the full range of the platform's capability.
Capital¶
Same minimum ratio floors as all ADIs. D-SIB buffer of 1.0% CET1 (all four major banks, Macquarie likely). LAC/TLAC (Loss Absorbing Capacity / Total Loss Absorbing Capacity) requirements for MSFIs are being finalised by APRA from January 2026. AT1 capital is retained in the Australian framework.
Full IRB approach (APS 113) available and used by current APRA-approved entities at this tier. Output floor applies.
Liquidity¶
Full LCR (≥ 100%) and NSFR (≥ 100%) as Category 1 ADIs. No change from current SFI requirements in terms of metrics; the three-tier reform's enhanced MSFI obligations focus more on resolution planning and governance than liquidity metrics per se.
Resolution planning¶
Full recovery and resolution planning obligations. APRA's finalising LAC/TLAC framework from January 2026 will apply primarily to MSFIs. No FCS difference — all ADIs covered by the Financial Claims Scheme equally.
FAR obligations¶
Enhanced Financial Accountability Regime notifications apply to MSFIs, with more granular accountability mapping and stricter APRA engagement requirements than SFI-level FAR obligations.
Platform relevance¶
MSFI configuration is a stretch goal for this platform — these entities use bespoke infrastructure. However, demonstrating MSFI-level compliance capability positions the platform credibly for all tiers. The key additive requirements versus AU-SFI are: LAC/TLAC tracking (capital structure module), enhanced FAR accountability map, and enhanced resolution plan integration.
Tier-specific regulations¶
Regulations that apply exclusively or in a materially different way to this tier:
| Reg ID | Title | Status |
|---|---|---|
| au-aps-330 | APS 330 Public Disclosure | live |
Tier-specific policies¶
Policies that apply exclusively to this tier (not all tiers in the jurisdiction):
| Code | Title | Status |
|---|---|---|
| CLQ-004 | Interest Rate Risk in the Banking Book (IRRBB) Policy | Draft |
Tier-specific modules¶
Modules deployed exclusively for this tier:
| Module | Title | Status |
|---|---|---|
| MOD-032 | LCR / NSFR calculator | Deployed |
Compiled 2026-05-22 from source/entities/entity-tiers/AU-MSFI.yaml