What the IASB proposal changes

Under the proposal, interest rate-sensitive financial assets, financial liabilities and eligible future transactions are aggregated into underlying portfolios and allocated to repricing time bands, resulting in net repricing risk exposure by time bucket.

The risk mitigation objective reflects management’s target profile and defines the extent to which net repricing risk is mitigated using interest rate derivatives, including the mitigated rate and relevant repricing horizon.

For measurement, benchmark derivatives are applied. The resulting Risk Mitigation Adjustment defers aligned derivative fair value changes and releases them to profit or loss in line with the repricing of the underlying portfolios, while residual changes are recognised immediately.

Significant challenges in banking practice

CET1-driven equity management is not always eligible under RMA

Dynamic portfolio rotations portfolio changes can trigger unintended P&L volatility

Proxy hedges are typically not economically effective. RMA mechanics do not reflect the reality of marketable derivatives purchase.

Centralised risk management faces strict RMA eligibility and documentation rules

How RMA works – an explanation in 5 steps

  • Define underlying portfolios (assets, liabilities, eligible future transactions) and allocate to repricing time bands.
  • Determine net repricing risk exposure by time bucket and anchor it in risk limits and IRRBB governance.
  • Set the risk mitigation objective (mitigated rate, horizon, extent) and link to the derivatives actually traded.
  • Construct benchmark derivatives purely for measurement, calibrated to represent the objective in PV terms.
  • Recognize the risk mitigation adjustment and define release logic aligned to repricing; book residual misalignment to P&L and disclose transparently.

Where implementation projects typically stumble

  • Eligibility & portfolio perimeter: what is in the scope, including behavioral items and future transactions.
  • Objective design: mitigated rate and horizon choices that work for ALM and accounting.
  • Benchmark derivative construction: consistent PV calibration, controls, and auditability.
  • Operationalization: time-band allocation, model inputs, data lineage, change management.
  • Performance & disclosure story: reconciling “economic effectiveness” with required transparency.

Our support – your added value

We support institutions across governance, risk management and financial reporting, focused on bridging IRRBB practice with RMA mechanics: 

  • Target operating model and RMA design options (portfolio structure, objectives, policies)
  • Eligibility & perimeter assessment, including future transactions and behavioural assumptions.
  • Benchmark-derivative methodology and measurement controls
  • Systems & data impact assessment (ALM, treasury, accounting subledgers, reporting)
  • Documentation package (governance, testing, controls) and disclosure blueprint
  • Comment-letter support and fieldwork readiness planning aligned to the IASB timetable

BDO’s integrated accounting, regulatory and risk advisory capabilities enable you to navigate the proposed requirements efficiently and position your organization for a smooth and well-governed implementation once the final standard is issued.

Reach out to our team – we’re happy to support you.

This article was written by

Rist, Lukas
German Public Auditor, Partner, Financial Services