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NZ Group 1 — D-SIB

Tier ID NZ-G1
Jurisdiction NZ
Status Current
Asset threshold > NZD 100 billion
Capital methodology IRB-eligible
Liquidity framework LCR-NSFR-MFCR
OBR applicable Yes
Disclosure tier Full
D-SIB eligible Yes

Notes

The four NZ-incorporated subsidiaries of Australian major banks (ANZ NZ, ASB, BNZ, Westpac NZ). All are designated NZ D-SIBs. Group 1 banks are the only NZ deposit takers currently RBNZ-accredited for the IRB approach to credit risk. From ~2028 they will be required to hold internal Loss Absorbing Capacity (LAC) instruments issued to their Australian parent groups. Capital buffers — Prudential Capital Buffer (PCB) 5.5% — include the D-SIB surcharge. AT1 capital has been removed from the NZ framework; all Tier 1 must be CET1.

Profile

Group 1 is the highest tier under the RBNZ Proportionality Framework published in March 2024 under the Deposit Takers Act 2023. It currently contains four entities — the NZ-incorporated subsidiaries of the four major Australian banks — each with total assets well above the NZD 100 billion threshold.

Capital

Group 1 banks are the only NZ deposit takers currently RBNZ-accredited for the Internal Ratings-Based (IRB) approach to credit risk. An IRB output floor of 85% of standardised RWA applies, ensuring that IRB risk weights cannot fall below 85% of what the standardised approach would produce on the same portfolio.

The Prudential Capital Buffer (PCB) is set at 5.5%, incorporating the D-SIB surcharge. This buffer sits above the minimum ratios (CET1 4.5%, Tier 1 7.0%, Total Capital 9.0%). Breaching the buffer triggers automatic dividend and discretionary distribution restrictions.

Additional Tier 1 (AT1) capital has been removed from the NZ framework — all Tier 1 must be CET1. Tier 2 capital and the new Loss Absorbing Capacity (LAC) instrument class remain. LAC — internally-issued subordinated debt to Australian parent groups with mandatory write-down/conversion features — is being designed for consultation in 2027 and will take effect from 2028 with a phase-in period.

Liquidity

Full LCR (≥ 100%, 30-day horizon), NSFR (≥ 100%, 1-year horizon), and NZ-specific MFCR (Minimum Core Funding Ratio, ≥ 75%) all apply. The MFCR requires a minimum proportion of funding to come from stable retail deposits and long-term wholesale instruments, providing a structural liquidity buffer additional to the global LCR/NSFR standards.

Resolution and OBR

OBR (Open Bank Resolution) pre-positioning is required where RBNZ includes OBR as a resolution tool in the deposit taker's resolution plan. All Group 1 banks are expected to maintain OBR readiness. The platform must support atomic haircut application to all eligible account balances, real-time unfrozen-balance display, and full logging for RBNZ examination.

Disclosure

Full quarterly prudential disclosure statements (board-approved) plus annual statements. Full BCBS Pillar 3 remuneration disclosure. The DTA Disclosure Standard (draft) will replace BS11 when the DTA takes full effect in December 2028.

Governance

Separate Audit, Risk, and Remuneration Board Committees required. Majority independent board. Director independence limit of 9 years / 3 terms. Enhanced RBNZ engagement on board appointments.

Platform relevance

A platform customer classified as NZ-G1 requires the full module set with no simplifications. The capital module (MOD-033) must support IRB RWA calculation and output floor. The liquidity module (MOD-032) must compute LCR, NSFR, and MFCR. The OBR module (MOD-143) must be active and tested. Full Pillar 3 disclosure output is required.

The first likely customer tier for this platform is NZ-G3 or NZ-G2; NZ-G1 represents the most demanding configuration and is documented here for completeness and future extensibility.

Applicable non-core standards

  • Governance
  • Risk Management
  • IRRBB
  • Operational Resilience
  • OBR Pre-positioning
  • Outsourcing
  • Cyber Resilience
  • Lending (LVR/DTI)

Tier-specific regulations

Regulations that apply exclusively or in a materially different way to this tier:

Reg ID Title Status
nz-dta-lending DTA Lending Standard Draft
nz-dta-obr DTA OBR Standard Draft
nz-dta-outsourcing DTA Outsourcing Standard Draft

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
CLQ-007 Climate Risk Management Policy Draft
REP-012 TCFD Climate Disclosure Policy Draft

Tier-specific modules

Modules deployed exclusively for this tier:

Module Title Status
MOD-032 LCR / NSFR calculator Deployed
MOD-143 Open Bank Resolution pre-positioning Deployed

Compiled 2026-05-22 from source/entities/entity-tiers/NZ-G1.yaml