Should the ECL on debt instruments classified at fair value through OCI under IFRS9 be included within the calculation of the amount to be added back to CET1 as set in Article 473a.2 ( “static approach”)?
At the date of transition to IFRS 9, for debt instruments that were measured at fair value under IAS 39 (e.g. debt instruments classified as “available for sale”) and are measured at fair value through OCI under IFRS 9, the ECLs do not reduce the carrying amount in the statement of financial position, which remains at fair value. Instead, a loss allowance is recognised against OCI as ‘accumulated impairment amount’, with no impact on the total Equity and, consequently, no impact on the CET1 capital.
Therefore, doubts arise on whether the ECLs on debt instruments classified at fair value through OCI under IFRS9 shall be included within the calculation of the amount to be added back to CET1 as set in Article 473a.2 (“static approach”).
Two alternative views are possible to answer to this question.
Article 473a of the Regulation (EU) No. 575/2013 establishes that, under the “static approach”, institutions are required to calculate the difference between the expected credit losses determined in accordance with paragraphs 5.5.5 and 5.5.3 of IFRS 9 at the implementation date (Article 473a(2)(b)(i)) and the amount of impairment losses determined in accordance with paragraphs 63,64, 65, 67, 68 and 70 of IAS 39 determined at 31 December 2017 or the day before the initial application of IFRS 9 (Article 473a(2)(b)(ii)). The resulting amount is the one to be considered for the application of the transitional arrangements.
The same logic, with the exclusion of credit-impaired instruments, is valid for the “dynamic approach” as established in paragraphs 3 and 4 of Article 473a.
This being said, it is important to note that Article 473a does not distinguish expected credit losses recognised for instruments measured at amortised cost from expected credit losses recognised for instruments measured at fair value through other comprehensive income - FVOCI. For this reason, impairment losses on debt instruments classified as FVOCI should, therefore, be included in the calculation required by Article 473a as suggested in the alternative 1 presented by the submitter.