AU ADI — Significant Financial Institution (three-tier, proposed)¶


Tier ID	`AU-SFI-3T`
Jurisdiction	AU
Status	Proposed — not yet operative
Asset threshold	> AUD 30 billion (proposed three-tier framework)
Effective from (est.)	2027-12-31
Capital methodology	IRB-eligible
Liquidity framework	LCR-NSFR
OBR applicable	No
Disclosure tier	Full
D-SIB eligible	No

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 middle tier under APRA's three-tier framework. Threshold raised from current AUD 20 billion to AUD 30 billion. ADIs currently between AUD 20 billion and AUD 30 billion will be individually reviewed by APRA for potential reclassification to Non-SFI-3T. Retains full APS 330 disclosure, full LCR/NSFR, and full CPS 511 obligations. Distinct from the current AU-SFI because the AUD 30bn threshold creates a materially different set of entities; some current SFIs will graduate to AU-MSFI, some will step down to AU-NonSFI-3T. The platform must demonstrate compliance against both AU-SFI (current) and AU-SFI-3T (proposed) simultaneously.

Profile¶

The SFI tier under APRA's proposed three-tier framework represents the middle category — large and complex ADIs that are significant to the financial system but not at the systemic scale of the five MSFIs. The threshold moves from the current AUD 20 billion to AUD 30 billion, meaning approximately nine entities would fall into this category after the reform.

Status: Proposed — not yet operative. This tier co-exists with AU-SFI (the current operative framework) in the platform's obligation model. Both must be supported simultaneously.

Transition from AU-SFI¶

ADIs currently designated as SFIs with assets between AUD 20 billion and AUD 30 billion will be individually reviewed by APRA before the reform takes effect. APRA will consider complexity and group structure in addition to asset size. Some may retain SFI status; others may be reclassified to non-SFI.

ADIs crossing the AUD 30 billion threshold upward from non-SFI receive a minimum 12-month transition period (extendable by APRA) before SFI obligations fully apply.

Obligations¶

AU-SFI-3T carries essentially the same obligation set as the current AU-SFI:

Full APS 330 Pillar 3 disclosure (mandatory)
LCR + NSFR (Category 1 ADI)
Full CPS 511 remuneration obligations
Full APS 220 risk management
Full FAR accountability obligations
IRB approach available where APRA-approved (in practice limited to the largest banks)

The key differences from AU-MSFI are: no LAC/TLAC requirement, no enhanced FAR notification requirements, and lower capital buffer expectations (no additional D-SIB buffer for non-D-SIB SFIs).

Platform relevance¶

From a platform configuration perspective, AU-SFI-3T is nearly identical to AU-SFI. The primary reason to maintain them as separate tiers is:

Threshold change: a bank at AUD 25 billion is an SFI now but potentially not under the reform
Obligation scope: any enhanced MSFI-specific requirements don't cascade to this tier
Future-proofing: APRA may introduce tier-specific requirements for SFI-3T over time

The compliance report for an AU SFI client should reference both AU-SFI (current, operative) and AU-SFI-3T (proposed, planning horizon) simultaneously.

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-SFI-3T.yaml