Capital Adequacy

ICAAP Framework Development

Riskweise builds Internal Capital Adequacy Assessment Process (ICAAP) frameworks for GCC banks, covering Pillar II risk identification and materiality, capital adequacy methodology, governance structures, multi-year capital projections, risk appetite linkage, and SREP submission readiness.

ICAAP frameworks are calibrated to Basel III/IV principles and the supervisory expectations of CBUAE, SAMA, CBB, QCB, CBK and CBO, with explicit linkage between ICAAP scenario assumptions, stress testing outputs, and recovery planning.

Methodology

How we approach it.

01, Component

Risk identification & materiality

Quantification of Pillar II risks not captured under Pillar I · liquidity, IRRBB, concentration, reputation, strategic risk, and others as relevant. Materiality mapping against capital base, with explicit thresholds and governance.

02, Component

Capital adequacy methodology

Economic capital computation, buffer design, and stress integration. Multi-year capital projections under baseline and adverse conditions. Methodology paper documents all assumptions, calibrations, and sensitivity analyses for supervisory review.

03, Component

Governance & documentation

Policy design, internal oversight, Board approval pathway. ICAAP report and Board pack templates standardised for annual submission cycles. Documentation built to withstand external audit and supervisory examination.

04, Component

Capital planning integration

Linkage with strategic planning, profitability targets, and risk appetite. Integration with stress testing scenarios, recovery planning triggers, and dividend / capital action governance, so ICAAP is operationally connected to business decisions, not a once-a-year compliance exercise.

05, Component

SREP & supervisory readiness

Template preparation, narrative documentation, and regulator engagement. Gap assessment against Basel III/IV and local supervisory expectations, with explicit remediation roadmap where gaps exist.

What we deliver

Concrete outputs.

  • ICAAP / Pillar II Policy document
  • ICAAP Methodology Guidelines
  • ICAAP capital adequacy tool / model (Excel-based, fully editable)
  • Capital planning framework with multi-year projections
  • Risk appetite linkage with KRI dashboards
  • ICAAP report and Board pack, supervisory-ready
  • SREP submission templates and supporting narrative
  • Integration framework with stress testing and recovery planning
Who this is for

The fit.

  • Banks implementing ICAAP for the first time
  • Banks responding to supervisory feedback on ICAAP framework
  • Banks integrating ICAAP with strategic capital planning
  • Banks preparing for first SREP cycle
  • Banks consolidating ICAAP across cross-border subsidiaries
  • Mid-sized banks transitioning from light-touch to full ICAAP
Regulatory references

Primary sources.

The frameworks, standards and regulator guidance our work is calibrated to. Open in a new tab to read alongside.

Common questions

Questions we get asked.

Is ICAAP mandatory for banks in the GCC?

Yes. All six GCC central banks, CBUAE, SAMA, CBB, QCB, CBK and CBO, require licensed banks to maintain an ICAAP framework, submitted at least annually with Board approval. The level of granularity expected scales with institutional size and complexity. Smaller banks and NBFCs face lighter requirements but still need a defensible framework.

Which Pillar II risks should we quantify?

The minimum set typically includes concentration risk, IRRBB (interest rate risk in the banking book), liquidity risk, and strategic / business risk. Most GCC banks also quantify reputation risk, model risk, and compliance / conduct risk. Materiality assessment determines the depth of quantification per risk type, material risks need full economic capital methodology; immaterial risks need documented monitoring with thresholds.

How does ICAAP integrate with stress testing?

ICAAP and stress testing share scenario assumptions but answer different questions. Stress testing quantifies P&L and capital impact under specific shocks; ICAAP determines whether the bank holds enough capital to withstand those impacts under its specific risk profile. Riskweise builds the two with shared scenario libraries, so the stress test outputs flow directly into ICAAP capital adequacy projections, with no reconciliation gap.

Do you handle SREP / supervisory submissions?

Yes. We prepare the full SREP submission pack, narrative documentation, capital adequacy templates, supporting evidence, and brief the bank team for regulator dialogue. Where gaps exist between current state and supervisory expectations, we develop a remediation roadmap that the Board can approve as part of the ICAAP submission itself.

How long does an ICAAP framework build take?

A first-time ICAAP build for a mid-sized bank takes 14-18 weeks from kickoff to a Board-approved submission pack. Banks updating an existing framework typically run 8-12 weeks. Complex multi-jurisdictional banks with subsidiary consolidation can run 20-26 weeks. The methodology and documentation are reusable across years, so subsequent annual cycles are materially shorter.

What does the deliverable look like: Excel?

The ICAAP model itself is an Excel-based capital adequacy tool with full Pillar II risk quantification, scenario integration, multi-year projection logic, and Board reporting templates. Every formula is open and editable. Methodology, governance, and policy documents are delivered as Word artefacts. The full pack is ready for supervisory review on delivery, with no further packaging required. What you do not get is a 200-page report with Excel outputs nobody inside the bank understands: the calculation engine is the deliverable, and your team is trained to run it.

Does the Central Bank of the UAE require banks to have an ILAAP?

Yes, though it has not yet defined one. Paragraph 101 of the CBUAE ICAAP Guidance (C 52/2017 GUI, effective 1 April 2021) expects the ICAAP and the ILAAP to inform each other on underlying assumptions, stress test results and forecast management actions, and the Large Exposures Regulation requires concentration risk to be covered in both. Paragraph 5 of the same Guidance says the Central Bank plans to issue separate detailed requirements for the ILAAP. As at 13 September 2026 no such requirements are on the CBUAE Rulebook, so there is no prescribed ILAAP format or UAE submission date. A draft ILAAP reporting guideline has been circulated to banks and is not public. The substance is already binding: the twelve qualitative criteria in the Regulations re Liquidity at Banks (Circular 33/2015, effective 1 July 2015) require a Board-set liquidity risk tolerance, regular internal liquidity stress tests, a formal contingency funding plan, a cushion of unencumbered high-quality liquid assets and a funds transfer pricing framework, with the framework, the plan and the stress results shared with the Central Bank on request.

What is an ILAAP?

The Internal Liquidity Adequacy Assessment Process: a bank's own Board-owned assessment of whether its liquidity and funding are adequate to meet its obligations as they fall due, in normal conditions and under its own stress scenarios. It is the liquidity counterpart of the ICAAP under Pillar 2 of Basel, and it is not a ratio. A bank can meet its regulatory liquidity ratios, in the UAE ELAR and ASRR or, for banks approved to use them, LCR and NSFR, and still fail its ILAAP if it cannot show how it knows it would stay liquid under stress. It covers governance, liquidity risk tolerance, measurement, stress testing, the contingency funding plan, funds transfer pricing and the bank's own conclusion on its liquidity adequacy.

What should a UAE bank build for its ILAAP before the CBUAE guideline is issued?

What Circular 33/2015 and its Guidance Manual (effective 1 December 2015) already require, written up so it can be reordered into the final format. That means a quantitative liquidity risk tolerance, such as the funding gap the bank accepts by maturity bucket under normal and stressed conditions; liquidity stress tests that cover the scenarios listed in the Guidance Manual and share their assumptions with the ICAAP scenario set; a contingency funding plan with escalation criteria that say when it is invoked; monitored early warning indicators; a documented funds transfer pricing framework; and a record of independent challenge. Islamic banks add the Internal Sharia Supervision Committee approvals for liquidity instruments required by the Standard re Liquidity at Islamic Banks. SAMA's ILAAP guideline, in force since 2021, is the nearest published GCC model for the document itself, but its annual submission timetable is SAMA's, not the UAE's.

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