UAE Central Bank inspections – common IFRS 9 findings

As the UAE’s financial landscape matures into a global powerhouse, the Central Bank of the UAE (CBUAE) has intensified its supervisory lens on IFRS 9 Financial Instruments. Recent inspections and the release of updated Model Management Guidance (MMG) underscore a shift from basic implementation to “high-fidelity” compliance. For banks, the focus has moved beyond simply having an Expected Credit Loss (ECL) model to ensuring that every assumption behind it can withstand rigorous regulatory stress.

Critical Deficiencies Identified in Recent Cycles

Examination findings frequently highlight that many institutions struggle with the “dynamic” nature of IFRS 9. The standard is not a “set-and-forget” model but a living framework that must reflect the current economic pulse of the Emirates.

Model “Drift” and Calibration:

A recurring finding is the failure to properly recalibrate models to reflect actual default experiences. If a bank’s predicted Probability of Default (PD) significantly varies from its historical reality without a clear, documented reason, regulators view this as a red flag for model risk.

The Over-Reliance on Overlays:

Many banks use “management overlays” (manual adjustments to model outputs) to account for risks the models cannot see, such as geopolitical shifts or real estate volatility. However, the CBUAE has noted a lack of robust governance around these overlays, often finding them poorly justified or lacking a clear “exit strategy” once data becomes available.

Segmenting Sharia-Compliant Portfolios:

For Islamic banks, a common finding involves the “SPPI” (Solely Payments of Principal and Interest) test. Applying conventional debt-based criteria to complex, risk-sharing Islamic contracts like Mudarabah requires a level of nuance that some automated systems still struggle to achieve.

The Path Toward “Future-Ready” Reporting

To bridge these gaps, the CBUAE is increasingly pushing for SupTech (Supervisory Technology) integration. Banks are now expected to move toward:

Granular Data Warehousing:

Transitioning away from legacy silos into integrated data lakes that allow for “look-through” analysis of collateral and borrower behavior.

Forward-Looking Macro-Scenarios:

Moving beyond simple “Base, Upside, Downside” cases to include more sophisticated variables like oil price sensitivity and interbank liquidity forecasts specific to the GCC region.

Independent Model Validation:

Ensuring that the team checking the model is truly independent of the team that built it—a structural requirement that is often a point of contention in smaller financial institutions.

Conclusion

The era of “approximate compliance” is over. UAE Central Bank inspections now demand a high level of transparency and mathematical rigor. Institutions that treat IFRS 9 as a strategic risk-management tool—rather than a mere accounting burden—will not only pass inspections but also gain a significant competitive advantage through more accurate pricing and capital allocation.

CBUAE inspections are raising the bar on IFRS 9 compliance. Are your models, overlays, and governance truly inspection-ready?

Fineit provides specialized IFRS 9 advisory and implementation services in the UAE, helping banks move from basic compliance to regulator-grade excellence.

Speak with Fineit to strengthen your IFRS 9 framework and future-proof your regulatory reporting.