The RBI has sought feedback on the discussion paper from various stakeholders, prior to the issuance of the guidelines.
According to ICRA, the final guidelines are expected to be notified by FY2024 for implementation from April 1, 2025.
In February 2016, the RBI had initially notified the implementation of IND-AS from April 1, 2018.
It had also sought proforma IND-AS from banks starting September 30, 2016.
However, the implementation of IND-AS was subsequently deferred.
The methodology/basis of computation of ECL is central to IND-AS and migration to ECL-based loss provisioning will be a major step towards the eventual shift to an IND-AS regime for banks.
“The non-performing advances (NPA) levels of banks are likely to touch decadal lows by March 2024.
With further improvement in profitability and capital cushions in the near term, we believe the timing is apt for banks to implement the ECL-based provisions," said Aashay Choksey, Vice President and Sector Head – Financial Sector Ratings, ICRA.
Under ECL, ‘financial assets’ are to be classified as Stage 1, 2 or 3, depending on their credit risk profile with Stage 2 and 3 loans having higher provisions based on the historical credit loss patterns observed by banks.
This will be in contrast to the existing approach of incurred loss provisioning, whereby step-up provisions are made based on the time the account has remained in the NPA category.
ICRA said that shifting to ECL-based provisioning will entail a one-time provisioning requirement on such Stage 2 and 3 exposures apart from other off-balance sheet exposures.
“While the RBI has proposed a maximum time frame of five years after the date of implementation for spreading out these provisions, ICRA expects some banks to raise external capital sooner to manage the impact of the transition in a better manner."
The discussion paper has also proposed a relaxed classification of 60+ days past due (dpd) standard loans as a part of Stage 2 loans (30+ dpd followed by most non-banks at present).
It has asked banks to carry ECL provisions on off-balance sheet exposures, including undisbursed credit lines.
While the overall ECL provisions will be based on the historical loss patterns observed by banks, the RBI will also specify a minimum floor.
Choksey added that as the provision coverage on existing NPAs is reasonably high for the banking system, the incremental ask on these NPAs will largely remain limited.
“Further, while the overdue wholesale loans of banks have reduced significantly, the overdues in the retail segment have increased post the onset of the Covid-19 pandemic. Our discussions with a few banks indicate that the transitioning impact to IND-AS could be as high as up to 300-400 bps, including the provisioning for ECL," he said.
