Credit Underwriting, Risk Management and Provisioning

Credit risk is entering a new phase. Across recent supervisory reviews, regulatory discussions and audit findings, a consistent message is emerging: banks can no longer rely on historically strong portfolio performance as evidence of resilience. Weakening underwriting standards, complex loan structures, risk-sensitive pricing gaps, refinancing vulnerabilities and fragmented monitoring are increasingly coming under scrutiny.

The European Central Bank’s supervisory priorities for 2026–2028 reinforce this direction, placing greater emphasis on the ability of institutions to identify, price, monitor and capitalise risks from the point of origination. As higher interest rates, changing collateral values, geopolitical uncertainty, macroeconomic volatility and evolving regulatory requirements reshape the credit environment, forward-looking risk assessment is becoming fundamental to both regulatory resilience and sustainable profitability.

For banks, this means moving beyond traditional backward-looking indicators towards a more integrated approach to credit risk management bringing together underwriting, risk-sensitive pricing, portfolio oversight, capital planning, provisioning and stress testing. Supervisors are increasingly challenging institutions to demonstrate how borrowers would withstand adverse conditions, whether collateral values remain robust, and whether lending returns adequately compensate for expected losses and capital consumption.

Our latest publication brings together key observations from supervisory focus areas, regulatory reviews and year-end audit findings, highlighting the themes and priorities that are likely to shape the next cycle of regulatory and external audits for both Significant and Less Significant Institutions. More importantly, it explores how banks can translate these lessons into stronger frameworks, better risk data and more effective early-warning capabilities, not simply to meet regulatory expectations, but to embed a forward-looking risk culture that supports resilience and sustainable risk-adjusted returns.

At BDO Germany, we support institutions in turning supervisory expectations into practical and sustainable improvements in credit risk management—from risk origination and portfolio monitoring through to governance, provisioning and capital management.

Horizonal View on Credit Markets & Regulation

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