## tarea2025076-source-pdf

## Source details

**Canonical URL:** [tarea2025076-source-pdf](https://www.imf.org/-/media/files/publications/tar/2025/english/tarea2025076-source-pdf.pdf)

## Other formats

- [Markdown version](/-/media/files/publications/tar/2025/english/tarea2025076-source-pdf.pdf.md)
- [Structured JSON version](/-/media/files/publications/tar/2025/english/tarea2025076-source-pdf.pdf.json)

---

### Mission and scope
- At the request of the Reserve Bank of Zimbabwe (RBZ), the Monetary and Capital Markets Department (MCM) conducted a hybrid mission: a virtual mission from November 25 to 29, 2024, and an in-person visit to Harare, Zimbabwe, from March 17 to 21, 2025, to assist the RBZ in finalizing the updated capital regulations based on the Basel III Capital Framework.
- Meetings: Mr. Philip Madamombe (Director, RBZ Bank Supervision, Surveillance and Financial Stability Division (BSSFSD)), Mrs. Norah Mukura (Deputy Director), Dr. Jeremiah Borerwe (Chief Bank Examiner), other supervisors responsible for Basel III implementation, and representatives of Zimbabwe’s banks.
- Financing: TA financed by the Financial Sector Stability Fund as a follow-up to the Financial Sector Stability Review (FSSR).

### Key findings and overall assessment
- Priority: advancing the capital framework in Zimbabwe is a high priority, as recommended by the FSSR and previous TA missions.
- Current framework status:
  - Under Zimbabwe’s current capital framework (2011), banks calculate capital for credit risk using the Basel I regime; for market and operational risk, Basel II standardized approaches are used.
  - Since 2012, RBZ has conducted a parallel run of banks’ capital calculations based on a modified Basel II approach for credit risk.
  - With IMF support, RBZ has been implementing certain elements of Basel III, using proportionality and considering Zimbabwe’s particularities.
- Implementation status highlights:
  - RBZ draft regulation mostly aligned with Basel III but requires specific adjustments across capital definition, credit risk, operational risk, market risk, buffers, leverage, large exposures, reporting templates, and supervisory resources.
  - Strong recommendation: conduct a Quantitative Impact Study (QIS) and public consultation prior to approval of the regulation.

### Capital definition and capital conservation buffer
- Findings:
  - Capital definition in RBZ draft regulation is mostly aligned with Basel III; definitions of CET1, Tier 1 and Tier 2 require minor adjustments.
  - Additional Tier 1 instruments: review trigger point of write-down mechanism in case of recalibration of minimum capital requirements.
  - Treatment of revaluation gains from investment properties: two options—consider as CET1 or as Tier 2; conservative approach to revaluation of land and buildings recommended.
  - Consider including provisions recognizing qualifying instruments issued by consolidated subsidiaries and held by third parties.
- Regulatory adjustments recommended (examples):
  - Exclude balance sheet items with uncertain loss-absorbing capacity; avoid double leveraging.
  - Include adjustments for cumulative gains/losses due to changes in own credit risk on fair valued liabilities; defined benefit pension fund assets and liabilities; investments in own shares; reciprocal cross-holdings; investments in capital of entities outside regulatory consolidation.
- Buffers:
  - Draft implements capital conservation buffer in addition to existing Domestic Systemically Important Bank (D-SIB) buffer.
  - Current regulation requires D-SIBs to fulfill D-SIB buffer with Tier 1 capital; should be updated to CET1 under Basel III.
  - Note: countercyclical capital buffer not in scope of this TA; recommended for future TA.

### Standardized Approach for Credit Risk (SCRA)
- General:
  - Draft follows SCRA consistent with Basel III; reduces dependence on external ratings and introduces new asset classes and risk weights (RW).
- Specific recommendations:
  - Assess adequacy of lower RW for retail and general corporate exposures.
  - Include definition for Small and Medium-Sized Enterprises (SME): Basel Framework SME definition—reported annual sales for consolidated group <= €50 million; RBZ to assess appropriate local threshold.
  - Include a Credit Risk Mitigation (CRM) section and update supervisory haircuts (Basel III supervisory haircuts defined in chapter CRE22.50).
  - Consider risk weight mapping table for foreign sovereigns based on external ratings; otherwise exposures receive RW of 100 percent.
  - Decide rule for exposures to multilateral development banks (MDB): criteria or explicit list; highly rated MDB eligible for 0% RW.
  - Subordinated debt exposures: risk-weight at 150 percent.
  - Speculative unlisted equity exposures: consider RW at 400 percent.
  - Exclude asset class “covered bonds” due to non-existence in local market.
  - General rule: exposures not assigned to any specific asset class shall be risk-weighted at 100 percent.
- QIS:
  - BSSFSD should conduct a QIS to gather granular bank data on impact of new concepts, asset classes and RW on RWA.

### Standardized Approach for Operational Risk
- Draft alignment:
  - RBZ draft for operational risk capital calculation aligns with Basel III Standardised Approach.
- Conceptual elements:
  - Business Indicator components determine the Business Indicator Component (BIC) via marginal coefficient α.
  - Internal Loss Multiplier (ILM) captures historical loss experience; LC = 15 times average annual operational risk losses over previous 10 years (as referenced in formula elements).
- ILM recommendations:
  - Set ILM equal to 1 for all banks or exclude it from metrics for simplification.
  - Preserved guidance and threshold: "for banks where the sum of all Business Indicator (BI) components... is less than 1 billion dollars, the Internal Loss Multiplier (ILM) component... should be set equal to 1."
  - Rationale: Zimbabwean banks are not expected to exceed this cap; neutralizing ILM expected not to materially impact operational risk capital results.
  - Require all banks to develop and manage an operational risk loss database independent of ILM use; supports future ILM activation/recalibration and supervisory monitoring.
- Recalibration and multiplier:
  - Multipliers used historically to estimate RWA equivalents were adjusted to 8.33 (1/12 percent) for operational risk.
  - To achieve intention of higher capital targets (12 percent total capital and 8 percent Tier 1), a multiplier of 8.33 (1/12 percent) instead of 12.5 (1/8 percent) was defined.
  - Changing the RWA multiplier without proportionally recalibrating operational risk metrics neutralizes expected increase of capital for operational risk and can reduce capital for requirements unchanged or increased less than 50 percent.

### Simplified Alternative Standardized Approach (SSA) for Market Risk
- Alignment:
  - RBZ draft aligns with Basel III SSA and incorporates full SSA methodology, including scaling factors and capital requirements for equity and commodity risks, and improves trading book identification criteria.
- Current practice:
  - Banks currently apply Basel II.5 Standardized Approach (SA) for interest rate risk and foreign exchange risk; equity and commodity components were not previously required.
- Recalibration and multiplier:
  - To align with higher capital targets, parameters equal to 8 percent applied to equity and foreign exchange risks were raised to 12 percent while other components kept unchanged.
  - A multiplier of 8.33 (1/12 percent) instead of 12.5 (1/8 percent) was used to calculate equivalent RWA for market risk to avoid double recalibration.
  - Risk: Changing the RWA multiplier without proportionally recalibrating market risk metrics neutralizes expected capital increases for market risk and reduces capital for other requirements.
- QIS:
  - BSSFSD should conduct a QIS to estimate impact of SSA implementation; study should measure impact on capital requirements due to scaling factors and capital requirement for equity and commodity risks and assess need for a phase-in period.
  - The study should measure the impact on capital requirements due to implementation of Basel III SSA, which is expected to be at least 20 percent.
- Missing/minor SSA recommendations:
  - Require 3 percent of the bank’s gross positions in commodities for commodities risk.
  - Provide guidance on treatment of derivatives for interest rate risk and include table for horizontal disallowance parameters.
  - Establish cap for "minor operations" currencies in FX metrics; 5% cap of total currencies exposures (as in LCR) suggested.
  - Exclude references to other approaches (not SSA) from draft; create specific section for trading vs banking book criteria; order MRC components as per formula.

### Large Exposures (LEX)
- Draft alignment and improvements:
  - Use of Tier 1 capital (instead of total capital) for calculation of LEX limits.
  - Exclusion of 75 percent total capital limit to single members of a corporate group.
  - More detailed criteria for economic interdependence, reporting requirements, and immediate notification of breaches.
- QIS:
  - BSSFSD should conduct a QIS to assess impact of changes, including effect of changing metric reference from Capital Base to Tier 1 Capital, banks’ capacity to identify economic interdependence, and need for a phase-in period.

### Leverage Ratio (LR)
- Capital measure:
  - Numerator: Tier 1 capital, as defined in the updated minimum capital requirements.
- Exposure measure recommendations:
  - Denominator should include total assets (on-balance sheet) and off-balance sheet items.
  - Draft includes rules for derivatives and Securities Financing Transactions (SFT) per Basel III.
  - RBZ should assess recognition of bilateral netting agreements for derivatives and SFT; include eligibility provisions if allowed.
  - RBZ should confirm existence/materiality of triparty repo in the market to adjust regulation accordingly.
- QIS:
  - QIS should consider LR to assess if this requirement may become binding, particularly for banks with large share of low risk-weighted assets.

### Liquidity disclosure and monitoring (LCR and NSFR)
- Disclosure:
  - Recommendation: RBZ to ensure banks disclose LCR and other liquidity risk information to the public.
  - Priority: High MT; Status: Regulation issued, but not yet in force.
- Monitoring objectives/actions:
  - Assure data quality for liquidity monitoring.
  - Map liquidity risk aggregate and by relevant currencies (domestic and US$).
  - Identify idiosyncratic liquidity issues requiring supervisory action.
  - Monitor liquidity during stress and inform RBZ board and relevant departments.
  - Monitor compliance with LCR minimum and act on breaches.
  - Assess accuracy of public LCR disclosures by banks.
  - Priority: High MT; Status: Implementation in progress (aggregate LCR and by currency monitored; validation process implemented; plans underway to fully implement liquidity monitoring process).
- NSFR:
  - Approve new NSFR regulation; NSFR Standard and Template finalized and to be subjected to RBZ Quality Assurance Process.
  - Priority: High MT; Status: Advanced stage of implementation.

### Reporting templates and supervisory resources
- Reporting templates:
  - Development deferred until final draft regulation and Basel III concepts are well understood.
  - Recommendation: further TA mission to assist RBZ with updating prudential reporting templates used by BSSFSD.
- Supervisory resources:
  - Implementation will raise supervisory workload due to new metrics and increased data volume.
  - Implementation of Basel standards handled by Financial Stability, Policy Research and Resolution unit with headcount of only 4 people.
  - Recommendation: review BSSFSD resources to ensure effective supervision, including adequate headcount and skills to conduct Basel III implementation project.

### Project timeline, capacity building and outreach
- Project extension:
  - The FSSR Follow-up project was extended up to August 31st, 2026.
  - Note preserved: "Before being extended, the FSSR Follow-up Project was designed to finish on December 31, 2024."
- Capacity building:
  - In-person mission focused on capacity building of RBZ supervisory team and participation in Bankers Association of Zimbabwe event.
  - About 30 supervisors from the BSSFSD participated in a two-day targeted training on Basel III capital framework.
  - IMF experts presented on Pillar 1 capital requirements and prudential limits.

### Recommendations (summary from Table 1)
- 1. Finalize the draft regulation on updating capital requirements and prudential limits more closely with Basel III standards by incorporating TA recommendations and submit the draft for public consultation.
  - Priority: High
  - Timeframe: I (Immediate: <6 months)
- 2. Conduct a QIS with banks’ support to estimate impact on banking system of updating capital requirements and prudential limits, including:
  - a. Capital definition and capital conservation buffer;
  - b. Capital requirement for credit risk;
  - c. Capital requirement for market risk;
  - d. Capital requirement for operational risk;
  - e. Large exposures;
  - f. Leverage ratio.
  - Priority: High
  - Timeframe: ST (Short term: with results from 6 to 12 months)
- 3. Approve the new regulation on capital requirements and prudential limits.
  - Priority: High
  - Timeframe: ST
- 4. Update the BSSFSD prudential reporting templates to align with updated regulation framework.
  - Priority: Medium
  - Timeframe: MT (Medium term: with results from 12 to 18 months)
- 5. Review BSSFSD’s resources to ensure effective supervision of updated capital framework, including adequate headcount and skills for Basel III implementation.
  - Priority: Medium
  - Timeframe: I

### Key technical and numeric points preserved
- ILM guidance and threshold: "for banks where the sum of all Business Indicator (BI) components... is less than 1 billion dollars, the Internal Loss Multiplier (ILM) component... should be set equal to 1."
- Recalibration multiplier applied historically: "multipliers used to estimate RWA equivalents were adjusted to 8.33 (1/12 percent) for both market and operational risks."
- Historical capital ratios set by RBZ in 2012: "Total Capital ratio to 12 percent and the Tier 1 capital ratio to 8 percent."
- Basel III minimums referenced: "According to Basel III Framework, the minimum ratio of 8% is required to total capital and 6% to Tier 1 capital."
- Project extension date: "up to August 31st, 2026."
- Training participation: "About 30 supervisors from the BSSFSD participated in a two-day targeted training on Basel III capital framework."
- Timeframe definitions: Immediate: <6 months; Short term: with results from 6 to 12 months; Medium term: with results from 12 to 18 months.

### Selected banking sector indicators and statistics (figures preserved as reported)
- Institutions: 14 commercial banks, 4 building societies, and 1 savings bank.
- Total assets: ZiG161.39 billion, which correspond to 18 percent of GDP (December 31, 2024).
- Foreign shareholding: Of 19 banks, 7 banks have foreign shareholding, with a market share of over 51 percent.
- System-wide capital and ratios (as reported, preservation of values):
  - All banks were compliant with the minimum capital adequacy requirements on December 31, 2024.
  - Banking sector average capital adequacy ratio: 34.91 percent.
  - Banking sector average Tier 1 ratio: 31.69 percent.
  - Regulatory minimums: capital adequacy 12 percent; Tier 1 8 percent.
- Asset quality and liquidity:
  - NPLs to total loans ratio: 3.37 percent (December 31, 2024); 2.09 percent (December 31, 2023).
  - BSSFSD September 2024 data: 82 percent of bank deposits were in foreign currency, mainly USD.
  - Exchange rate: 1 USD=25.7985 ZiG (December 31, 2024; Reserve Bank of Zimbabwe).
  - Nominal GDP: USD 35.224 billion (December 31, 2024; IMF).
- Time series excerpts (values preserved as reported):
  - Total Assets (Billion): Dec-22 3,814.43; Mar-23 5,676.25; Jun-23 27,284.88; Sep-23 28,355.17; Dec-23 34,412.23; Mar-24 106,782.6; Jun-24 77.554 ZiG; Sep-24 139.195 ZiG; Dec-24 161.582 ZiG.
  - Total Loans (Billion): Dec-22 1,293.51; Mar-23 1,969.12; Jun-23 10,190.14; Sep-23 9,699.42; Dec-23 11,264.45; Mar-24 40,052.00; Jun-24 27.452 ZiG; Sep-24 51.411 ZiG; Dec-24 55.930 ZiG.
  - Net Capital Base (Billion): Jun-23 5,948.89; Sep-23 6,316.68; Dec-23 7,657.91; Mar-24 24,608.14; Jun-24 16.447 ZiG; Sep-24 33.468 ZiG; Dec-24 38.424 ZiG.
  - Total Deposits (Billion): Jun-23 14,776.75; Sep-23 16,075.83; Dec-23 19,469.49; Mar-24 60,629.76; Jun-24 43.600 ZiG; Sep-24 76.102 ZiG; Dec-24 89.066 ZiG.
  - Net Profit (Billion): Jun-23 4,553.21; Sep-23 4,671.78; Dec-23 5,768.05; Mar-24 14,771.46; Jun-24 10.419 ZiG; Sep-24 20.565 ZiG; Dec-24 26.751 ZiG.
  - Return On Assets: Mar-23 17.43%; Jun-23 4.92%; Sep-23 26.11%; Dec-23 23.69%; Mar-24 23.97%; Jun-24 22.83%; Sep-24 13.37%; Dec-24 20.84%; 23.52% as listed.
  - Return On Equity: Mar-23 54.33%; Jun-23 16.62%; Sep-23 74.60%; Dec-23 55.63%; Mar-24 68.99%; Jun-24 61.53%; Sep-24 35.74%; Dec-24 55.87%; 64.72% as listed.
  - Capital Adequacy Ratio (benchmark 12): Dec-22 37.51%; Mar-23 41.05%; Jun-23 40.48%; Sep-23 43.15%; Dec-23 37.34%; Mar-24 36.99%; Jun-24 46.15%; Sep-24 37.25%; Dec-24 34.98%.
  - Tier 1 Ratio (benchmark 8): Dec-22 26.92%; Mar-23 27.85%; Jun-23 35.35%; Sep-23 27.28%; Dec-23 25.77%; Mar-24 30.39%; Jun-24 40.13%; Sep-24 32.64%; Dec-24 31.75%.
  - Loans To Deposits (benchmark 70): Mar-23 55.67%; Jun-23 62.09%; Sep-23 68.96%; Dec-23 60.34%; Mar-24 49.27%; Jun-24 55.98%; Sep-24 52.51%; Dec-24 58.70%; 58.83% as listed.
  - Non-Performing Loans Ratio (benchmark 5): Jun-22 1.58%; Sep-22 3.30%; Dec-22 3.63%; Mar-23 2.34%; Jun-23 2.09%; Sep-23 2.13%; Dec-23 2.02%; Mar-24 3.19%; Jun-24 3.38%.
  - Liquidity Ratio (benchmark 30): reported values include 59.50%, 57.65%, 59.88%, 61.74%, 60.53%, 61.97%, 59.52%, 57.53%, 58.83%.
  - Liquidity Coverage Ratio (benchmark 100%): reported values include 174.12%, 241.11%, 307.72%, 287.32%, 315.80%, 282.66%, 267.19%.

_Imf Technical Assistance Report | Preface — tarea2025076-source-pdf_

### Preface ................................................................................................................

### tarea2025076-source-pdf - Preface

### Mission and scope
- At the request of the Reserve Bank of Zimbabwe (RBZ), the Monetary and Capital Markets Department (MCM) conducted a hybrid mission: a virtual mission from November 25 to 29, 2024, and an in-person visit to Harare, Zimbabwe, from March 17 to 21, 2025, to assist the RBZ in finalizing the updated capital regulations based on the Basel III Capital Framework.
- Meetings were held with Mr. Philip Madamombe (Director, RBZ Bank Supervision, Surveillance and Financial Stability Division (BSSFSD)), Mrs. Norah Mukura (Deputy Director), Dr. Jeremiah Borerwe (Chief Bank Examiner), other supervisors responsible for Basel III implementation, and representatives of Zimbabwe’s banks.
- The TA was financed by the Financial Sector Stability Fund as a follow-up to the Financial Sector Stability Review (FSSR).

### Key findings and assessments
- Priority: advancing the capital framework in Zimbabwe is a high priority, as recommended by the FSSR and previous TA missions.
- Current framework status:
  - Under Zimbabwe’s current capital framework (2011), banks calculate capital for credit risk using the Basel I regime; for market and operational risk, Basel II standardized approaches are used.
  - Since 2012, RBZ has conducted a parallel run of banks’ capital calculations based on a modified Basel II approach for credit risk.
  - With IMF support, RBZ has been implementing certain elements of Basel III, using proportionality and considering Zimbabwe’s particularities.
- Capital definition:
  - RBZ draft regulation is mostly aligned with Basel III.
  - Recommendation: review the trigger point of the write-down mechanism for Additional Tier 1 instruments in case of a recalibration of minimum capital requirements.
  - Recommendation: maintain a conservative approach to the revaluation of land and buildings (properties).
  - Many regulatory adjustments should be included in the draft to ensure closer alignment with Basel III.
- Credit risk:
  - RBZ draft follows the Standardized Credit Risk Assessment (SCRA) approach, reducing dependence on external ratings.
  - Recommendations: assess adequacy of lower risk weights (RW) for retail and general corporate exposures; include definition for Small and Medium-Sized Enterprises (SME) in the draft; include a Credit Risk Mitigation (CRM) section.
- Operational risk:
  - RBZ draft is in line with the Basel III Framework, consistent with the March 2023 TA mission.
  - TA recommendation: set the Internal Loss Multiplier (ILM) component equal to 1 for all banks or exclude it from metrics for simplification.
  - Note: neutralizing the ILM is expected not to impact operational risk capital results in Zimbabwe1.
  - Recommendation: require all banks to develop and manage an operational risk loss database, independent of ILM use2.
  - Footnote preserved: "According to Basel III methodology, for banks where the sum of all Business Indicator (BI) components, which represent the total exposure to operational risk, is less than 1 billion dollars, the Internal Loss Multiplier (ILM) component of the metrics should be set equal to 1. Banks in Zimbabwe are not expected to exceed this cap."
- Market risk:
  - RBZ draft aligns with the Simplified Alternative Standardised Approach (SSA) of Basel III and has incorporated the full SSA methodology, including scaling factors and capital requirements for equity and commodity risks3.
  - Current practice: banks calculate market risk by applying Basel II.5 Standardized Approach for interest rate risk and foreign exchange risk; equity and commodity components were not previously required.
  - Recommendation: assess impacts of recalibrating parameters in RWA equivalents for market and operational risks; recalibration can produce unintended consequences if multipliers and capital risk components are not adjusted proportionally.
  - Preserved numeric example: multipliers used to estimate RWA equivalents were adjusted to 8.33 (1/12 percent) for both market and operational risks.
- Buffers and leverage:
  - Draft regulation implements the capital conservation buffer, in addition to the existing Domestic Systemically Important Bank (D-SIB) buffer, and includes leverage ratio.
  - Current regulation requires D-SIBs to fulfill the requirement with Tier 1 capital; Basel III requires CET1.
  - The capital conservation buffer will provide an additional fixed layer of capital; both buffers can be used during times of stress but will trigger distribution constraints when breached.
  - The leverage ratio capital measure was updated considering Basel III; only the exposure measure requires revision.
- Large exposures:
  - Draft regulation aligns with Basel Framework and prudential limits and incorporates improvements recommended in March 2023 TA: use Tier 1 capital instead of total capital for large exposure limits; exclude the 75 percent total capital limit for single members of a corporate group; provide more detailed criteria for economic interdependence; specify reporting to supervisors; require immediate notification of breaches.
- Quantitative Impact Study (QIS) and consultation:
  - BSSFSD should gather information to estimate the impact of implementing Basel III in Zimbabwe.
  - Strong recommendation to conduct a QIS and public consultation prior to approval of the regulation.
  - Rationale: the draft introduces many changes to calculation and compliance; impacts on banks’ capacity and operationalization challenges need identification and discussion.
- Capacity building and outreach:
  - In-person mission focused on capacity building of RBZ supervisory team and participation in Bankers Association of Zimbabwe event.
  - About 30 supervisors from BSSFSD participated in a two-day targeted training on Basel III capital framework.
  - IMF experts presented on Pillar 1 capital requirements and prudential limits to raise awareness and obtain banking industry perspectives.
- Reporting templates and supervisory resources:
  - Development of prudential reporting templates deferred until final draft regulation is ready and Basel III concepts are well understood.
  - BSSFSD should review resources to ensure effective supervision, including adequate headcount and skills for Basel III implementation.
- Project timeline:
  - The FSSR Follow-up project was extended up to August 31st, 20265 to continue banking regulatory and supervisory reforms.
  - Note preserved: "Before being extended, the FSSR Follow-up Project was designed to finish on December 31, 2024."

### Recommendations (summary from Table 1)
- 1. Finalize the draft regulation on updating capital requirements and prudential limits more closely with Basel III standards by incorporating the recommendations of this TA and submit the draft for public consultation.
  - Priority: High
  - Timeframe: I (Immediate: <6 months)
- 2. Conduct a QIS with the banks’ support to estimate the impact on the banking system of updating capital requirements and prudential limits more closely with Basel III standards, including:
  - a. Capital definition and capital conservation buffer;
  - b. Capital requirement for credit risk;
  - c. Capital requirement for market risk;
  - d. Capital requirement for operational risk;
  - e. Large exposures;
  - f. Leverage ratio.
  - Priority: High
  - Timeframe: ST (Short term: with results from 6 to 12 months)
- 3. Approve the new regulation on capital requirements and prudential limits.
  - Priority: High
  - Timeframe: ST
- 4. Update the BSSFSD prudential reporting templates that provide supervisors with information on capital requirements and prudential limits, in line with the updated regulation framework.
  - Priority: Medium
  - Timeframe: MT (Medium term: with results from 12 to 18 months)
- 5. Review BSSFSD’s resources to ensure effective supervision of updated capital framework, including adequate headcount and skills to conduct the Basel III implementation project and to properly encompass all the changes in supervisory activities that the new framework requires.
  - Priority: Medium
  - Timeframe: I

### Technical and numeric points to preserve
- ILM guidance and threshold: "for banks where the sum of all Business Indicator (BI) components... is less than 1 billion dollars, the Internal Loss Multiplier (ILM) component... should be set equal to 1."
- Recalibration multiplier applied historically: "multipliers used to estimate RWA equivalents were adjusted to 8.33 (1/12 percent) for both market and operational risks."
- Historical capital ratios set by RBZ in 2012: "Total Capital ratio to 12 percent and the Tier 1 capital ratio to 8 percent."
- Basel III minimums referenced: "According to Basel III Framework, the minimum ratio of 8% is required to total capital and 6% to Tier 1 capital."
- Project extension date: "up to August 31st, 2026."
- Training participation: "About 30 supervisors from the BSSFSD participated in a two-day targeted training on Basel III capital framework."
- Timeframe definitions: Immediate: <6 months; Short term: with results from 6 to 12 months; Medium term: with results from 12 to 18 months.

*IMF Technical Assistance Report | Preface — tarea2025076-source-pdf*

### 2.      In the 2019 FSSR follow-up TA roadmap, it was agreed with the authorities to address

### II. Banking Sector Overview and III. The Implementation of Basel III Capital Standards

### Context and TA engagement
- 2019 FSSR follow-up TA roadmap agreed with authorities to address identified weaknesses in Zimbabwe’s banking supervision, resolution, and crisis-management arrangements.
- RBZ requested TA to support implementation of the reforms outlined in the TA Roadmap and Project Plan to safeguard financial stability by strengthening regulatory and supervisory frameworks, institutional capacity, and technical capacity of staff.
- Multiple TA missions undertaken:
  - 2019: joint LEG/MCM TA to assist enhancement of the RBZ Act, the Banking Act, and the Deposit Protection Corporation Act.
  - 2019–2020: two TAs on strengthening risk-based supervision.
  - 2021–2024: five TA missions supporting implementation of consolidated supervision, Basel III liquidity and capital standards.
  - AFRITAC South delivered three TA missions to enhance banking supervision.
  - MCM provided TA on strengthening bank resolution and crisis management frameworks.
- The mission covered is the second mission dedicated to implementation of Basel capital standards; it was conducted May 8-19, 2023, and reviewed drafts of updated capital framework and provided advice on remaining issues and next steps.
- The mission included an awareness session for banking institutions (30 participants) and two days of training for about 30 supervisors from the BSSFSD.

### Banking sector structure and key indicators (as presented)
- Institutions and aggregate size:
  - 14 commercial banks, 4 building societies, and 1 savings bank.
  - Total assets: ZiG161.39 billion, which correspond to 18 percent of GDP (December 31, 2024).
  - Of 19 banks, 7 banks have foreign shareholding, with a market share of over 51 percent.
- Capitalization and supervisory assessment:
  - RBZ stated that the banking sector continues to demonstrate resilience and adequate capitalization.
  - All banks were compliant with the minimum capital adequacy requirements on December 31, 2024 (based on prudential returns).
  - Banking sector average capital adequacy ratio: 34.91 percent.
  - Banking sector average Tier 1 ratio: 31.69 percent.
  - Regulatory minimums: capital adequacy 12 percent; Tier 1 8 percent.
  - Banking sector core capital growth driven mainly by revaluation gains from foreign exchange denominated assets and investment properties.
- Asset quality and liquidity:
  - NPLs to total loans ratio: 3.37 percent (December 31, 2024), deterioration from 2.09 percent (December 31, 2023); both within internationally acceptable threshold of 5 percent.
  - Recommendation: continue enhancing supervisory monitoring to ensure timely identification of NPLs and accurate asset classification and provisioning.
  - Banks began calculating and reporting LCR to RBZ in June 2023.
  - LCR reporting indicates large amounts of HQLA buffers relative to stress-scenario liquidity needs.
  - BSSFSD September 2024 data: 82 percent of bank deposits were in foreign currency, mainly USD.
- Currency and macro context:
  - New currency introduced April 5, 2024: Zimbabwe Gold (ZiG), anchored by a composite basket of foreign currency and precious minerals (mainly gold) held as reserves by the RBZ.
  - Exchange rate: 1 USD=25.7985 ZiG (December 31, 2024; Reserve Bank of Zimbabwe).
  - Nominal GDP: USD 35.224 billion (December 31, 2024; IMF).
  - Upon introduction of ZiG, banking sector converted ZW$ balances into ZiG balances.

### A. Capital definition and capital conservation buffer — findings and recommendations
- Findings on draft regulation:
  - Capital definition in RBZ draft regulation is mostly aligned with Basel III; aims to enhance capital quality.
  - Definitions of CET1, Tier 1 and Tier 2 require minor adjustments.
  - Additional Tier 1 instruments: update trigger point of write-down mechanism in case of recalibration of minimum capital requirements.
  - Treatment of revaluation gains from investment properties: two options—consider as CET1 or as Tier 2.
  - RBZ encouraged to evaluate conservative treatment for revaluation of land and buildings through quantitative impact studies.
  - With ongoing operationalization of Consolidated Supervision Framework, provisions recognizing instruments issued by consolidated subsidiaries and held by third parties that meet inclusion criteria for CET1, Tier 1 or Tier 2 could be included.
- Regulatory adjustments:
  - Adjustments that exclude balance sheet items with uncertain loss-absorbing capacity and avoid double leveraging require updates.
  - RBZ should consider amending regulation to include adjustments for:
    - cumulative gains and losses due to changes in own credit risk on fair valued liabilities;
    - defined benefit pension fund assets and liabilities;
    - investments in own shares (treasury stock), own other capital instruments;
    - reciprocal cross-holdings in the capital of banking, financial and insurance entities;
    - investments in the capital of banking, financial and insurance entities outside scope of regulatory consolidation.
- Capital buffers:
  - Draft regulation implements a capital conservation buffer in addition to the existing Domestic Systemically Important Bank (D-SIB) buffer.
  - Prudential standard established in 2020 to deal with D-SIBs includes a buffer requirement; current regulation requires D-SIBs to fulfill requirement with Tier 1 capital—this should be updated to CET1 under Basel III implementation.
  - Capital conservation buffer provides an additional fixed layer of capital for all banks; both buffers usable in stress but trigger distribution constraints when capital levels fall within the buffer range.
  - Note: countercyclical capital buffer was not in scope of this TA mission; recommended to be included in a future TA.

### B. Standardized Approach for Credit Risk — findings and recommendations
- General approach and benefits:
  - Draft regulation follows the Standardized Credit Risk Assessment (SCRA) approach consistent with Basel III; does not require external ratings.
  - SCRA increases risk sensitivity and reduces dependence on external ratings by introducing new asset classes and risk weights (RW).
- Specific recommendations:
  - Assess adequacy of lower RW for retail and general corporate exposures:
    - Basel III allows lower RW for retail exposures arising from transactors; RBZ should evaluate appropriateness using credit operations data.
    - Basel III allows lower RW for corporates identified as “investment grade”; RBZ should carefully evaluate which local corporates qualify given qualitative definition and absence of external ratings.
    - Note: “transactors” definition and example RW: transactors — obligations where balance repaid in full at scheduled repayment date for previous 12 months; RW of 45%.
    - “Investment grade” corporate definition provided in source.
  - Regulation should include the definition for Small and Medium-Sized Enterprises (SME):
    - Basel Framework SME definition: reported annual sales for consolidated group <= €50 million.
    - RBZ should assess appropriate annual sales threshold considering local environment.
  - BSSFSD should conduct a QIS (Quantitative Impact Study) to gather granular information from banks on impact of new concepts, asset classes and RW on RWA.
- Additional regulatory elements recommended to enhance the regulation:
  - Assess need to include a risk weight mapping table for foreign sovereigns based on external ratings; otherwise exposures receive RW of 100 percent.
  - Decide rule for exposures to multilateral development banks (MDB): provide criteria for identifying highly rated MDBs or explicitly list them; highly rated MDB eligible for 0% RW.
  - Include provision for subordinated debt exposures to be risk-weighted at 150 percent.
  - Evaluate inclusion of specific provision for speculative unlisted equity exposures to be risk-weighted at 400 percent.
  - Exclude asset class “covered bonds” due to non-existence in local market.
  - Add general rule: exposures not assigned to any specific asset class shall be risk-weighted at 100 percent.
  - Include a Credit Risk Mitigation (CRM) section in the regulation; incorporate provisions from existing Guideline No: 1-2011/BSD and update supervisory haircuts (Basel III supervisory haircuts defined in chapter CRE22.50 of the consolidated Basel framework).

### C. Standardized Approach for Operational Risk — findings and recommendations
- Draft alignment and methodology:
  - RBZ draft regulation for operational risk capital calculation is in line with Basel III Standardised Approach.
  - Conceptual assumptions:
    - Operational risk increases at an increasing rate with a bank’s income, represented by marginal coefficient α applied to the Business Indicator component.
    - Banks with historically greater operational risk losses are more likely to experience operational risk losses in future, represented by the Internal Loss Multiplier (ILM).
  - Figure 1 summarizes metrics (as provided): ILDC, SC, FC, LC and formula elements; LC = 15 times average annual operational risk losses over previous 10 years.
- Recommendations on ILM and loss databases:
  - RBZ should consider establishing the ILM equal to 1 or excluding the component from metrics for capital calculation for operational risk:
    - Calculation of ILM requires a high quality 10-year operational losses database.
    - Low-quality loss databases that do not reflect totality of losses may estimate ILM <1 and thus lower capital requirement.
    - Draft regulation sets ILM = 1 if bank falls into lowest α bucket (Business Indicator (BI) <= 1 billion dollars), expected for all Zimbabwean banks; thus setting ILM = 1 or excluding it would not impact results materially.
  - RBZ should maintain requirement for an operational risk loss database for all banks, independent of ILM use, because:
    - Future activation of ILM component or recalibration of α ranges would require loss database data.
    - Internal loss database supports banks’ operational risk management and internal controls and is an important supervisory data source to identify fragilities and monitor adequacy of capital for operational risk.
  - TA recommendation: even if ILM is neutralized (ILM = 1 or excluded) to allow banks time to build sound loss databases, the requirement to create and maintain a loss database in line with Basel III should remain.

*IMF Technical Assistance Report — excerpts presented in the source content.*

### 24.        The RBZ should assess the impacts of recalibrating the RWA equivalent multiplier for

### 24.        The RBZ should assess the impacts of recalibrating the RWA equivalent multiplier for operational risk

### Operational risk recalibration: findings and implications
- To achieve the intention of requiring capital ratios higher than Basel III minimum requirements (12 percent for total capital and 8 percent for Tier 1 capital), a multiplier of 8.33 (1/12 percent) instead of 12.5 (1/8 percent) was defined to calculate the equivalent RWA for operational risk.
- Changing the RWA multiplier without proportionally recalibrating the operational risk metrics neutralizes the expected increase of capital for operational risk in the calculation of total capital.
- The total capital ratio had been raised by 50 percent (from 8 percent to 12 percent total capital); the recalibration approach provokes a reduction of capital for those requirements whose ratios remained unchanged or had increased less than 50 percent (CET1, Tier 1 and the buffers).
- Recommendation: RBZ should revise its strategies for recalibration to ensure that the consequences to be achieved match the objectives. See notes in Annex IV for more details.

### QIS recommendation for operational risk (BSSFSD)
- BSSFSD should conduct a QIS to estimate the impact of implementing the Basel III Standardized Approach for operational risk in Zimbabwe.
- The RBZ should develop a questionnaire to collect data from all banks to assess:
  - The impact of the new methodology on capital requirement level: the study should measure the impact on capital requirements due to the implementation of the Basel III Standardized Approach, as well as estimate the need for a phase-in period for its full implementation;
  - The scope of Business Indicators, which might be simplified by excluding those referring to financial activities not existent in Zimbabwe and not expected to be developed in the near future;
  - Banks’ capacity to collect data for the calculation of Business Indicator components: the study should assess any challenges banks may face when shifting to the calculation of Business Indicator components;
  - The need for an ILM component in the metrics: if banks fall into the lowest α bucket, the ILM would be equal to 1, which could postpone eventual supervisory concerns about the quality of banks’ loss databases to a later stage and focus on the implementation of the Business Indicator components as a first step.

### Simplified Alternative Standardized Approach (SSA) for market risk: alignment and changes
- The RBZ draft regulation for capital calculation for market risk is in line with the Simplified Alternative Standardised Approach (SSA) of the Basel III Framework.
- Currently, banks in Zimbabwe calculate capital for market risk by applying Basel II.5 Standardized Approach (SA) for interest rate risk and foreign exchange risk.
- Basel III SSA methodology uses the same Basel II.5 metrics, with the application of scaling factors to each component of the metrics. The RBZ draft regulation incorporates the full SSA methodology, including scaling factors and capital requirement for equity and commodity risks, and improves criteria for identifying trading book exposures.

### Market risk recalibration: findings and implications
- To achieve the intention of requiring capital ratios higher than the Basel III minimum requirement (12 percent for total capital and 8 percent for Tier 1), the parameters equal to 8 percent applied to exposures in equity and foreign exchange risks were raised to 12 percent while those applied to other risk components were kept unchanged.
- A multiplier of 8.33 (1/12 percent) instead of 12.5 (1/8 percent) was used to calculate the equivalent RWA for market risk, to avoid double recalibration.
- Changing the RWA multiplier and not proportionally recalibrating the market risk metrics neutralizes the expected increase of capital to market risk in the calculation of total capital, which ratio had been raised in 50% (from 8% to 12% total capital), and provokes a reduction of capital to those requirements which ratios remained unchanged or had increased less than 50% (CET1, Tier 1 and the buffers).
- Recommendation: RBZ should revise its strategies for recalibration to ensure that the consequences achieved match the regulator’s objectives. See Annex IV for clarification.

### QIS recommendation for market risk (BSSFSD)
- BSSFSD should conduct a QIS to estimate the impact of implementing the Basel III Simplified Alternative Standardized Approach for market risk in Zimbabwe.
- The RBZ should develop a questionnaire to collect data from all banks to assess the impact of the introduction of the scaling factors, as well as capital requirement for equity and commodity risks.
- The study should measure the impact on capital requirements due to the implementation of Basel III SSA, which is expected to be at least 20 percent, and assess the need for a phase-in period for its implementation.

### Missing requirements and minor SSA recommendations
- Missing elements in the draft regulation:
  - For commodities risk: it is necessary to require 3 percent of the bank’s gross positions in commodities.
  - For interest rate risk: guidance on the treatment of derivatives needs to be provided, and the table that presents the parameters for the calculation of horizontal disallowance is missing.
  - Establish a cap to quantify “[currencies with] ‘minor operations’” in the FX metrics to harmonize application among banks; the 5% cap of total currencies exposures, already used in the LCR methodology, would be adequate.
- Other minor recommendations:
  - Exclude from the draft any paragraph that refers to other approaches (not SSA) used to calculate capital for market risk;
  - Create a specific section to outline the criteria for identification of trading and banking book exposures;
  - Arrange the metrics of MRC components along the text in the same order they appear in the formula.

### Large Exposures: draft alignment and QIS
- The RBZ draft regulation on large exposures is in line with the Basel Framework and incorporates improvements:
  - Use of Tier 1 capital (instead of total capital) for the calculation of LEX limits;
  - Exclusion of the 75 percent total capital limit to single members of a corporate group;
  - More details on criteria for identifying economic interdependence;
  - More details on information to be reported to supervisors;
  - A requirement for banks to immediately inform supervisors of breaches on the limit.
- Recommendation: RBZ should conduct a QIS to assess the impact of the reviewed Large Exposures regulation on banks’ compliance with the limits, and collect additional data if necessary to assess:
  - The impact of changing the metric’s reference from Capital Base to Tier 1 Capital;
  - Banks’ capacity to identify economic interdependency among counterparties;
  - The need for a phase-in period for full implementation.

### Leverage Ratio (LR)
- Capital measure update:
  - The capital measure (numerator) of the LR is Tier 1, as defined in the rules to calculate the minimum capital requirements, and this is reflected in the updated regulation.
- Exposure measure recommendation:
  - The exposure measure (denominator) should comprise not only total assets (on-balance sheet items) but also off-balance sheet items.
  - The draft regulation includes rules for derivatives and Securities Financing Transactions (SFT) as prescribed by Basel III.
  - RBZ should assess if the regulation should allow bilateral netting agreements to be recognized in the calculation of derivatives and SFT; if allowed, provisions related to eligibility of netting agreements and net calculations must be included; if not, include provisions related to transaction-by-transaction calculation only.
  - RBZ should confirm existence and/or materiality of triparty repo in the market to adjust the regulation accordingly.
- QIS recommendation:
  - The QIS should consider the LR to assess if this requirement may become a binding constraint for any banks, particularly those with a large share of low risk-weighted assets.

### Reporting templates
- Developing prudential reporting templates was left for a later stage.
- Prerequisites: well-understood Basel III concepts and metrics, and a finalized version of the draft regulation.
- Further TA mission recommended to assist RBZ with updating prudential reporting templates used by BSSFSD to collect information on capital minimum requirements and prudential limits.

### Supervisory resources
- BSSFSD capacity concerns:
  - Enhancements to the regulatory framework will raise supervisory workload due to new metrics and increased reported data.
  - Implementation of Basel standards – liquidity and capital frameworks – are under the Financial Stability, Policy Research and Resolution unit with a headcount of only 4 people.
- Recommendation: review BSSFSD resources to ensure effective supervision of updated capital framework, including adequate headcount and skills to conduct the Basel III implementation project and encompass all changes in supervisory activities.

### Key banking sector statistics and indicators (as reported)
- Structure of the banking sector as of December 31, 2024: TOTAL = 161,333,480,814.54 ZiG; MARKET SHARE (percent) examples: CBZ 17.82, STANBIC BANK 15.01, ECOBANK 14.68, FBC 8.13, CABS 8.03, ZB BANK 6.06.
- Banking Sector Key indicators (selected entries, values preserved as reported):
  - Total Assets (Billion): Dec-22 3,814.43; Mar-23 5,676.25; Jun-23 27,284.88; Sep-23 28,355.17; Dec-23 34,412.23; Mar-24 106,782.6; Jun-24 77.554 ZiG; Sep-24 139.195 ZiG; Dec-24 161.582 ZiG.
  - Total Loans (Billion): Dec-22 1,293.51; Mar-23 1,969.12; Jun-23 10,190.14; Sep-23 9,699.42; Dec-23 11,264.45; Mar-24 40,052.00; Jun-24 27.452 ZiG; Sep-24 51.411 ZiG; Dec-24 55.930 ZiG.
  - Net Capital Base (Billion): Jun-23 5,948.89; Sep-23 6,316.68; Dec-23 7,657.91; Mar-24 24,608.14; Jun-24 16.447 ZiG; Sep-24 33.468 ZiG; Dec-24 38.424 ZiG.
  - Total Deposits (Billion): Jun-23 14,776.75; Sep-23 16,075.83; Dec-23 19,469.49; Mar-24 60,629.76; Jun-24 43.600 ZiG; Sep-24 76.102 ZiG; Dec-24 89.066 ZiG.
  - Net Profit (Billion): Jun-23 4,553.21; Sep-23 4,671.78; Dec-23 5,768.05; Mar-24 14,771.46; Jun-24 10.419 ZiG; Sep-24 20.565 ZiG; Dec-24 26.751 ZiG.
  - Return On Assets: Mar-23 17.43%; Jun-23 4.92%; Sep-23 26.11%; Dec-23 23.69%; Mar-24 23.97%; Jun-24 22.83%; Sep-24 13.37%; Dec-24 20.84%; (Dec-24?) 23.52% as listed.
  - Return On Equity: Mar-23 54.33%; Jun-23 16.62%; Sep-23 74.60%; Dec-23 55.63%; Mar-24 68.99%; Jun-24 61.53%; Sep-24 35.74%; Dec-24 55.87%; 64.72% as listed.
  - Capital Adequacy Ratio (benchmark 12): Dec-22 37.51%; Mar-23 41.05%; Jun-23 40.48%; Sep-23 43.15%; Dec-23 37.34%; Mar-24 36.99%; Jun-24 46.15%; Sep-24 37.25%; Dec-24 34.98%.
  - Tier 1 Ratio (benchmark 8): Dec-22 26.92%; Mar-23 27.85%; Jun-23 35.35%; Sep-23 27.28%; Dec-23 25.77%; Mar-24 30.39%; Jun-24 40.13%; Sep-24 32.64%; Dec-24 31.75%.
  - Loans To Deposits (benchmark 70): Mar-23 55.67%; Jun-23 62.09%; Sep-23 68.96%; Dec-23 60.34%; Mar-24 49.27%; Jun-24 55.98%; Sep-24 52.51%; Dec-24 58.70%; 58.83% as listed.
  - Non-Performing Loans Ratio (benchmark 5): Jun-22 1.58%; Sep-22 3.30%; Dec-22 3.63%; Mar-23 2.34%; Jun-23 2.09%; Sep-23 2.13%; Dec-23 2.02%; Mar-24 3.19%; Jun-24 3.38% (as presented across dates).
  - Liquidity Ratio (benchmark 30): values include 59.50%, 57.65%, 59.88%, 61.74%, 60.53%, 61.97%, 59.52%, 57.53%, 58.83% (as reported across dates).
  - Liquidity Coverage Ratio (benchmark 100%): reported values include 174.12%, 241.11%, 307.72%, 287.32%, 315.80%, 282.66%, 267.19% (as reported).

*IMF Technical Assistance Report | content supplied in the source PDF.*

### 6. The RBZ to ensure that banks disclose LCR and other liquidity risk

### 6. The RBZ to ensure that banks disclose LCR and other liquidity risk information to the public

### Liquidity disclosure requirement and status
- Recommendation: The RBZ to ensure that banks disclose LCR and other liquidity risk information to the public.
- Priority: High MT
- Status: Regulation issued, but not yet in force

### Liquidity risk monitoring process — objectives and actions
- Recommendation: The RBZ to review the liquidity risk monitoring process using data from the LCR and the monitoring tools, with the following objectives:
  - Assure an adequate quality level on data used to monitor the banks’ liquidity risk exposure.
  - Map the liquidity risk level of the supervised institutions, both in aggregate and by relevant currencies (domestic and US$), and monitor liquidity risk.
  - Identify any idiosyncratic liquidity issue in a specific bank that would lead to supervisory actions to address the problem.
  - Monitor the banks’ liquidity level during stress periods and keep the RBZ board and relevant departments informed about the liquidity issues and vulnerabilities.
  - Monitor the banks’ compliance with the LCR minimum requirement and take promptly actions when a bank reports a breach in the LCR.
  - Assess whether the LCR information banks are disclosing to the public is correct.
- Priority: High MT
- Status: Implementation in progress:
  - (i) aggregate LCR and by currency are being monitored;
  - (ii) validation process is implemented;
  - (iii) plans are underway to fully implement the liquidity monitoring process

### Related prudential regulation developments and statuses
- 8. Approve new NSFR regulation, ensure banks compute and report NSFR regularly, and examine banks’ compliance.
  - Priority: High MT
  - Status: Advanced stage of implementation: NSFR Standard and Template are finalized and to be subjected to the RBZ Quality Assurance Process
- 9. Draft a new version of capital definition in line with the Basel III requirements by incorporating notable advancements in:
  - Prudential adjustments
  - Capital instruments loss-absorbing capacity (going concern)
  - Capital buffers
  - Priority: High I
  - Status: Drafted
- 10. Draft updates in the current capital requirement for credit risk in line with the Basel III Standardised Approach by incorporating changes in:
  - asset classes
  - concepts
  - risk weights
  - Priority: High ST
  - Status: Drafted
- 11. Draft new regulation on the capital requirement for operational risk in line with the Basel III Standardised Approach
  - Priority: Medium ST
  - Status: Drafted
- 12. Draft updates to the current Standardised Approach (Basel 2.5 SA) to comply with the Basel III Simplified Alternative Standardised Approach (SSA), mainly aiming to:
  - apply scaling factors to the risk components
  - prepare to incorporate capital requirements for equity and commodity risks
  - Priority: Medium ST
  - Status: Drafted
- 13. Draft updates in the definition of trading book and banking book in line with the Basel III requirements
  - Priority: High ST
  - Status: Drafted
- 14. Draft updates to the current regulation on Large Exposures, mainly aiming to:
  - use Tier I Capital for setting the large exposure limits
  - adjust the large exposures’ limit requirements in line with the Basel III Framework
  - improve criteria for economic interdependence identification
  - revise the exemptions list in line with Basel III treatment for CRM Techniques and offsetting schemes
  - Priority: High I
  - Status: Drafted
- 15. Draft updates to the current regulation, mainly aiming to:
  - Update the capital definition in line with the Basel III Framework
  - consider the update of the exposure measure regarding the treatment of derivatives and Securities Financing Transactions (SFTs)
  - Priority: Medium ST
  - Status: Drafted
- 16. Review the Basel II prudential reporting template structure to incorporate all changes from the updated capital regulatory framework
  - Priority: High MT
  - Status: Not started
- 17. Based on the drafts, conduct impact studies to assess banks' capacity to implement and comply with the proposed changes in capital requirements and operational limits, in order to establish an appropriate implementation strategy
  - Priority: High MT
  - Status: Not started

*IMF Technical Assistance Report | tarea2025076-source-pdf - 6. The RBZ to ensure that banks disclose LCR and other liquidity risk information to the public*

---


_Source: https://www.imf.org/-/media/files/publications/tar/2025/english/tarea2025076-source-pdf.pdf_