AU ADI — Non-SFI¶
| Tier ID | AU-NonSFI |
| Jurisdiction | AU |
| Status | Current |
| Asset threshold | ≤ AUD 20 billion and not APRA-designated |
| Capital methodology | Standardised |
| Liquidity framework | MLH |
| OBR applicable | No |
| Disclosure tier | Simplified |
| D-SIB eligible | No |
Notes
The majority of Australian ADIs by count — includes most credit unions, building societies, mutual banks, and smaller regional banks. Standardised capital approach only (APS 112; APS 113 IRB not available). Category 2 ADI for liquidity — Minimum Liquidity Holdings (MLH) of at least 9% of liabilities (not LCR/NSFR). APS 330 Pillar 3 disclosure not mandatory (may be applied at APRA discretion). Simplified capital ratio calculation available for eligible non-SFIs under APS 110 Attachment A. CPS 511 remuneration standard applies with simplified obligations. This tier will be superseded by AU-NonSFI-3T when the APRA three-tier reform is finalised. The most likely AU customer tier for this SaaS platform — credit unions, building societies, and smaller mutual banks.
Profile¶
Non-SFI is the baseline category for Australian ADIs — the majority of ADIs by count. This includes most credit unions, building societies, mutual banks, and smaller regional banks with total assets at or below AUD 20 billion and not otherwise designated by APRA. This is the most likely initial AU customer tier for this SaaS platform.
Capital¶
Standardised approach (APS 112) only — IRB (APS 113) is not available. Minimum ratios: CET1 4.5%, Tier 1 6.0%, Total Capital 8.0%, plus the CCB of 2.5% CET1. No D-SIB buffer (no non-SFI entities are D-SIBs).
A simplified capital ratio calculation is available for eligible non-SFIs under APS 110 Attachment A, paragraph 3. This simplifies the risk-based capital ratio calculation, reducing complexity for smaller institutions.
AT1 capital is retained in the Australian framework. Tier 2 and AT1 count towards their respective ratio calculations under APS 111.
Liquidity¶
Non-SFIs are APRA Category 2 ADIs and use the Minimum Liquidity Holdings (MLH) framework instead of LCR/NSFR. The MLH requirement is a minimum of 9% of liabilities held in approved high-quality liquid assets. This is significantly simpler than the LCR outflow-rate methodology and does not require the granular cash-flow modelling that LCR demands.
The proposed APRA three-tier reform (AU-NonSFI-3T) contemplates a further simplified MLH framework for non-SFIs. Under the current framework, MLH remains the operative standard.
Implication for the platform: The liquidity module (MOD-032) computes LCR and NSFR for SFIs. Non-SFI clients need an MLH calculation — a distinct calculation mode. Comparable to the NZ Group 3 CFCR gap; both represent a simplified liquidity metric for smaller entities that requires separate platform support.
Public disclosure¶
APS 330 Pillar 3 disclosure is not mandatory for non-SFIs. APRA may direct specific non-SFIs to comply at its discretion. Baseline public reporting (annual reports, financial statements) is expected but is not mandated at the APS 330 level.
Governance¶
CPS 511 remuneration standard applies with simplified obligations for non-SFIs — primarily qualitative principles rather than the detailed performance adjustment and disclosure requirements applicable to SFIs. APS 220 Risk Management and APS 510 Governance apply to all ADIs including non-SFIs, with proportionate expectations.
AML/CTF¶
All ADIs are AUSTRAC reporting entities with the same AML/CTF programme obligation structure. There is no AUSTRAC size-based tier — the risk-based approach inherently proportions programme complexity to the entity's actual ML/TF risk exposure.
Platform relevance¶
An AU-NonSFI client configuration: MLH liquidity (not LCR/NSFR), standardised capital only, no mandatory APS 330 disclosure, simplified CPS 511 configuration. The capital module (MOD-033) uses APS 112 standardised RWA. The liquidity module (MOD-032) must support the MLH calculation mode — a gap to address alongside the NZ-G3 CFCR gap.
Tier-specific regulations¶
No regulations are tagged as exclusive to this tier. All regulations applicable to this jurisdiction apply under their default scope.
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 |
Compiled 2026-05-22 from source/entities/entity-tiers/AU-NonSFI.yaml