RBNZ releases its latest thematic: Risk Management Insights on practices in the deposit taking sector

Tracey Berry
February 2026
Funds

The Reserve Bank of New Zealand (RBNZ) has today published its thematic review on risk management practices in the deposit taking sector. The themes emerging sounding all-too familiar: Frameworks; Governance; Three lines of defence.

But the messaging is sharper. It’s not just having risk management documented, it’s making it work (which is afterall, the point).

Reading the paper is time well spent for all deposit-takers (and those aspiring), as is proceeding with the “self-assessment against the expectations, findings, good practices and recommendations outlined” in the report. Which RBNZ make clear is a “must” do supervisory expectation.

A few observations:

1. Show us how it works

RBNZ observed that institutions now have risk frameworks in place. But what stood out in the review were organisations that could demonstrate:

  • forward-looking risk identification (i.e., scenario analysis, stress testing, emerging risks)
  • practical, regular and proactive monitoring through dashboards and management information
  • regular, independent review of how the framework operates in practice

Gaps included non-financial risk and having fit-for-purpose tools in place.

2. Risk appetite should influence decisions

Risk appetite remains one of the weakest areas. The RBNZ is clear that risk appetite and risk management strategy should be:

  • board-owned
  • aligned to each other
  • embedded in day-to-day decisions
  • linked to escalation and consequences when limits are breached

If risk appetite doesn’t affect how decisions are made, supervisors are unlikely to view it as effective, no matter how well written it is.

3. Boards are expected to lean in harder on risk

The review highlights better practice where boards:

  • have the expertise to understand key and emerging risks
  • spend more time on risk discussions
  • receive reporting that enables challenge, not just information

The report also notes variation in CRO effectiveness, particularly where CRO roles are “dual-hatted”, calling out the need to ensure development is strong and teams are sufficiently resourced.

4. Three lines exist, but are challenged

Most organisations say they operate a three lines model. Though, in practice RBNZ found:

  • roles blurred between first and second line
  • resource constraints drove overlap (particularly for smaller firms)
  • limited independent assurance

5. Better, not more, risk reporting

RBNZ’s expectations for risk reporting are simple, it needs to be clear; timely; accurate and decision useful. To achieve this, firms need better use of technology and data.

Why this matters now

The RBNZ review feeds into the upcoming Risk Management Standard under the Deposit Takers Act (DTA), with exposure drafts expected in 2026 and implementation from 2028.

The institutions that will be best placed are the ones using this time to review their existing frameworks for effectiveness and who are putting in place programmes for continuous improvement now.

Mosaic is always happy to talk with clients about their DTA and Risk Management needs.

Read the RBNZ Risk Management Thematic Report.

RBNZ releases its latest thematic: Risk Management Insights on practices in the deposit taking sector

Published
February 2026
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The Reserve Bank of New Zealand (RBNZ) has today published its thematic review on risk management practices in the deposit taking sector. The themes emerging sounding all-too familiar: Frameworks; Governance; Three lines of defence.

But the messaging is sharper. It’s not just having risk management documented, it’s making it work (which is afterall, the point).

Reading the paper is time well spent for all deposit-takers (and those aspiring), as is proceeding with the “self-assessment against the expectations, findings, good practices and recommendations outlined” in the report. Which RBNZ make clear is a “must” do supervisory expectation.

A few observations:

1. Show us how it works

RBNZ observed that institutions now have risk frameworks in place. But what stood out in the review were organisations that could demonstrate:

  • forward-looking risk identification (i.e., scenario analysis, stress testing, emerging risks)
  • practical, regular and proactive monitoring through dashboards and management information
  • regular, independent review of how the framework operates in practice

Gaps included non-financial risk and having fit-for-purpose tools in place.

2. Risk appetite should influence decisions

Risk appetite remains one of the weakest areas. The RBNZ is clear that risk appetite and risk management strategy should be:

  • board-owned
  • aligned to each other
  • embedded in day-to-day decisions
  • linked to escalation and consequences when limits are breached

If risk appetite doesn’t affect how decisions are made, supervisors are unlikely to view it as effective, no matter how well written it is.

3. Boards are expected to lean in harder on risk

The review highlights better practice where boards:

  • have the expertise to understand key and emerging risks
  • spend more time on risk discussions
  • receive reporting that enables challenge, not just information

The report also notes variation in CRO effectiveness, particularly where CRO roles are “dual-hatted”, calling out the need to ensure development is strong and teams are sufficiently resourced.

4. Three lines exist, but are challenged

Most organisations say they operate a three lines model. Though, in practice RBNZ found:

  • roles blurred between first and second line
  • resource constraints drove overlap (particularly for smaller firms)
  • limited independent assurance

5. Better, not more, risk reporting

RBNZ’s expectations for risk reporting are simple, it needs to be clear; timely; accurate and decision useful. To achieve this, firms need better use of technology and data.

Why this matters now

The RBNZ review feeds into the upcoming Risk Management Standard under the Deposit Takers Act (DTA), with exposure drafts expected in 2026 and implementation from 2028.

The institutions that will be best placed are the ones using this time to review their existing frameworks for effectiveness and who are putting in place programmes for continuous improvement now.

Mosaic is always happy to talk with clients about their DTA and Risk Management needs.

Read the RBNZ Risk Management Thematic Report.

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