RBI’s Pillar 3 Proposes Disclosure of Liquidity Risks and Measures
Move from Narrative Disclosures to Structured Transparency
– Payal Agarwal, Partner | payal@vinodkothari.com
The draft Capital Adequacy Amendment Directions of RBI propose changes to the existing Directions in relation to the Pillar 3 disclosure requirements (Market Discipline). The amendments are proposed to be made towards better alignment of the regulatory disclosure framework with the Basel norms. In addition to the new disclosure requirements with respect to Liquidity Risks and Macro-prudential Supervisory measures, the Draft proposes a move from narrative disclosures to a more structured, comprehensive transparency.
Proposed to be effective from: quarter ended 30th September, 2026
Highlights of the proposal
- Banks to have formal disclosure policy for Pillar 3 data
- Key elements of the policy to be described in the year-end Pillar 3 report or cross- referenced to another location where they are available
- Formal attestation by one or more WTDs in writing that Pillar 3 disclosures have been prepared in accordance with the board-agreed internal control processes
- Safeguarding proprietary and confidential information:
- Disclosure not required for proprietary or confidential information that may reveal the position of a bank or contravene its legal obligations
- More general information about the subject matter including the fact that specific items of information have not been disclosed and the reasons thereof.
- Guiding principles of Pillar 3 disclosures specified
- Disclosures to be clear, comprehensive, meaningful, consistent and comparable
- Disclosure of data points for previous period not required in case of first-time reporting of a metric
- For permitted transitions, the transitional data shall be reported unless the bank is compliant with fully loaded requirements
- For regulatory disclosures on the website, archive period proposed to increase to 10 years, against existing 3 years’ requirement
Disclosure on Liquidity Risk Management measures
The proposed format, amongst others, incorporates a new field for liquidity related disclosures. This includes, qualitative and quantitative disclosures on liquidity risk management aspects, alongside disclosure of Liquidity Coverage Ratio (LCR) and Net Stable Funding Ratio (NSFR):
| Qualitative disclosures: LRM governance Funding strategy including policies on diversification and tenor Liquidity risk mitigation techniquesExplanation of stress testingOutline of contingency funding plans | Quantitative disclosures: Measurement tools for structural liquidity and cash flow projections Concentration limits on collateral pools and sources of fundingLiquidity exposures and funding needs and entity and branch level including limitations on transferability of liquidityBalance sheet and off-balance sheet items broken down into maturity buckets and the resultant liquidity gaps |
Contents of disclosure (Annex III)
|
Proposed Format |
Existing Format |
New Disclosures |
Frequency of Disclosure |
|---|---|---|---|
|
1. Overview of risk management, key prudential metrics, and RWA |
|||
|
Template KM1: Key metrics (at consolidated group level) |
New addition in the form of summary table, cross-linked to respective detailed tables |
|
Quarterly |
|
Table OVA: Bank risk management approach |
General qualitative disclosure requirement under Risk Exposure and Assessment |
More granular information such as risk governance structure, qualitative information on stress testing etc. |
Annual |
|
Template OV1: Overview of RWA |
No specific equivalent |
RWAs and minimum capital requirements broken down for various risk categories: credit, CCR, market, operational etc. |
Quarterly |
|
2. Linkages between financial statements and regulatory exposures |
|||
|
Table LIA: Explanations of differences between accounting and regulatory exposure amounts |
New table, some information overlap with Table DF-1: Scope of application |
Qualitative explanations on the differences observed between accounting carrying value and amounts considered for regulatory purposes |
Annual |
|
Table LIB: Outline of the differences in the scope of consolidation (entity by entity) |
Corresponds to Table DF-1: Scope of application |
– |
Annual |
|
Template LI1: Differences between accounting and regulatory scopes of consolidation and mapping of financial statement categories with regulatory risk categories |
No specific table; however, overlaps with Table DF-12: Composition of capital – reconciliation requirements |
Breakdown of each component of balance sheet by risk framework — credit risk, CCR, securitisation, market risk, or not subject to capital requirements/ capital deduction |
Annual |
|
Template LI2: Main sources of differences between regulatory exposure amounts and carrying values in financial statements |
No specific table; source of material differences between its total balance sheet assets (net of on-balance sheet derivative and SFT assets) as reported in its financial statements and its on-balance sheet exposures to be disclosed and detailed in line 1 of the common disclosure template. |
Detailed template covers sources of differences, viz., valuation differences, netting differences, provisions, and prudential filters — by risk category column. |
Annual |
|
Template PV1 – Prudent valuation adjustments (PVAs) |
– Only a single line-item within regulatory capital composition table |
Break down PVAs by type (CVA loss, closeout cost, early termination, model risk, operational risk, funding costs, administrative costs, other) and by instrument category (equity, rates, FX, credit) and book (trading / banking). |
Annual |
|
3 Composition of Capital |
|||
|
Table CCA – Main features of regulatory capital instruments |
Table DF-13: Main features of regulatory capital instruments |
– |
Ongoing, at least on a semi-annual basis |
|
Template CC1 – Composition of regulatory capital |
Table DF-11: Composition of capital |
– |
Semi-annual |
|
Template CC2: Reconciliation of regulatory capital to balance sheet |
Table DF-12: Composition of capital – reconciliation requirements |
Higher granularity provided under each line-item |
Semi-annual |
|
4 Remuneration |
|||
|
Table REMA – Remuneration policy |
Qualitative disclosures under Table DF-15: Disclosure requirements for remuneration |
Annual |
|
|
Template REM1 – Remuneration awarded during financial year |
Quantitative disclosures under Table DF-15: Disclosure requirements for remuneration |
More granular details sought |
Annual |
|
Template REM2: Special payments |
Annual |
||
|
Template REM3: Deferred remuneration |
Annual |
||
|
5. Credit Risk |
|||
|
Table CRA – General qualitative information about credit risk |
Table DF-3: Credit risk: general disclosures for all banks |
Specific disclosure w.r.t. credit risk function, viz.,
|
Annual |
|
Template CR1: Credit quality of assets |
Semi-annual |
||
|
Template CR2: Changes in stock of non-performing loans and debt securities |
Semi-annual |
||
|
Table CRB: Additional disclosure related to the credit quality of assets |
|
Annual |
|
|
Table CRC: Qualitative disclosure related to credit risk mitigation techniques |
Table DF-5: Credit risk mitigation: disclosures for standardised approaches |
– |
Annual |
|
Template CR3: Credit risk mitigation techniques – overview |
– |
Semi-annual |
|
|
Table CRD: Qualitative disclosures on bank’s use of external credit ratings under the standardised approach for credit risk |
Table DF-4 – Credit risk: disclosures for portfolios subject to the standardised approach (qualitative) |
Annual |
|
|
Template CR4: Standardised approach – credit risk exposure and Credit Risk Mitigation (CRM) effects |
– |
On-balance sheet and off-balance sheet exposures for each asset class:
|
Semi-annual |
|
Template CR5: Standardised approach – exposures by asset classes and risk weights |
Table DF-4 – Credit risk: disclosures for portfolios subject to the standardised approach (quantitative) |
Risk weight buckets increased; existing format divides into 3 major risk buckets |
Semi-annual |
|
6. Counterparty credit risk |
|||
|
Table CCRA – Qualitative disclosure related to counterparty credit risk |
Table DF-10: General disclosure for exposures related to counterparty credit risk |
– |
Annual |
|
Template CCR1 – Analysis of counterparty credit risk (CCR) exposure by approach |
Structured in a tabulated form with more granular data requirements |
Semi-annual |
|
|
Template CCR3 – CCR exposures by regulatory portfolio and risk weights |
Semi-annual |
||
|
Template CCR4 – Composition of collateral for CCR exposures |
Semi-annual |
||
|
Template CCR5 – Credit derivatives exposures |
|||
|
Template CCR6 – Exposures to central counterparties |
|||
|
7. Securitisation |
|||
|
Table SECA – Qualitative disclosure requirements related to securitisation exposures |
Table DF-6: Securitisation exposures: disclosure for standardised approach |
List of:
|
Annual |
|
Template SEC1 – Securitisation exposures in the banking book |
Bifurcation based on:
|
Semi-annual |
|
|
Template SEC2 – Securitisation exposures in the trading book |
Semi-annual |
||
|
Template SEC3 – Securitisation exposures in the banking book and associated regulatory capital requirements – bank acting as originator |
– |
Semi-annual |
|
|
Template SEC4 – Securitisation exposures in the banking book and associated capital requirements – bank acting as investor |
– |
Semi-annual |
|
|
8. Market Risk |
|||
|
Table MRA – Qualitative disclosure requirements related to market risk |
Table DF-7: Market risk in trading book |
Elaboration of qualitative disclosures, viz.,
|
Annual |
|
Template MR1 – Market risk under the standardised approach |
Classification of positions:
|
Semi-annual |
|
|
9. Operational Risk |
|||
|
Table ORA: Disclosure related to operational risk and operational resilience |
Table DF-8: Operational risk |
Elaboration of qualitative disclosures |
|
|
10. Interest rate Risk |
|||
|
Table IRRA: Disclosure related to Interest Rate Risk |
Table DF-9: Interest rate risk in the banking book (IRRBB) |
Elaborated qualitative disclosures |
Annual for qualitative disclosure and semiannual for quantitative disclosure |
|
11. Macroprudential supervisory measures |
|||
|
Template GSIB1 – Disclosure of G-SIB indicators |
– |
12 indicators used in the assessment methodology of the G-SIB framework |
Annual |
|
Template CCyB1 – Geographical distribution of credit exposures used in the countercyclical capital buffer |
– |
Geographical breakdown of private sector credit exposures (values and RWAs) and Countercyclical capital buffer rate for computation of the bank-specific countercyclical capital buffer rate and amount |
Semi-annual |
|
12. Leverage Ratio |
|||
|
Template LR1 – Summary comparison of accounting assets vs leverage ratio exposure measure |
Table DF 17- Summary comparison of accounting assets vs. leverage ratio exposure measure |
– |
Quarterly |
|
Template LR2 – Leverage ratio common disclosure template |
Table DF-18: Leverage ratio common disclosure template |
– |
Quarterly |
|
13. Liquidity |
|||
|
Table LIQA – Liquidity risk management |
– |
See above |
Annual |
|
Template LIQ1 – Liquidity coverage ratio (LCR) |
– |
Unweighted and weighted values of
|
Quarterly |
|
Template LIQ2 – Net stable funding ratio (NSFR) |
– |
Unweighted value by residual maturity and weighted value of
|
Semi-annual |

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