Provision Matrix
Define aging buckets, enter gross carrying amounts and historical loss rates. Per IFRS 9.B5.5.35.
Forward-Looking Adjustment
Required by IFRS 9.5.5.17. Purely historical rates are not IFRS 9 compliant.
Advanced Features
Optional: probability-weighted scenarios, movement schedule, specific assessment, and entity details.
IFRS 9 ECL Audit Working Paper Template — free PDF
Practical audit guide covering the simplified approach provision matrix methodology, forward-looking adjustment documentation template, probability-weighted scenario framework, IFRS 7.35H movement schedule template, common ISA 540 findings on ECL estimates, and industry benchmark loss rates for 12 sectors.
No spam. Unsubscribe anytime.
IFRS 9 ECL in United Kingdom — IFRS 9 (as adopted by UK)
The United Kingdom adopted IFRS 9 Financial Instruments as part of UK-adopted international accounting standards, effective for annual periods beginning on or after 1 January 2018. Following Brexit, the UK Endorsement Board (UKEB) assumed responsibility for endorsing IFRS standards for use in the UK. IFRS 9 as adopted by the UK is substantively identical to the IASB-issued version, including the expected credit loss impairment model in Section 5.5. The Financial Reporting Council (FRC) has issued thematic reviews and guidance that shape practical expectations for ECL measurement and disclosure. UK entities must navigate Companies Act 2006 reporting requirements alongside IFRS 9, and HMRC guidance on the tax deductibility of ECL provisions adds a further layer of complexity. The FRC Lab has published reports examining the quality of ECL disclosures among UK-listed entities, identifying areas where practice can be improved. UK companies reporting under IFRS 9 should pay particular attention to the FRC's expectations regarding forward-looking information, scenario weighting, and the transparency of significant judgements in their ECL estimates.
Regulatory Context — FRC
The FRC has conducted multiple thematic reviews of IFRS 9 ECL implementation since the standard became effective. Key areas of FRC scrutiny include the adequacy of forward-looking information incorporated into ECL models, the transparency of significant increase in credit risk (SICR) thresholds and staging criteria, and the quality of sensitivity disclosures for ECL estimates. The FRC's Corporate Reporting Review (CRR) team has written to companies requesting improvements in ECL disclosures, particularly around the explanation of macro-economic scenarios and their probability weightings. The FRC has also highlighted concerns about the use of management overlays and post-model adjustments, expecting entities to provide clear explanations of the nature, rationale, and quantified impact of any such adjustments. Following COVID-19 and subsequent economic disruptions, the FRC intensified its focus on how entities incorporate unprecedented economic conditions into their ECL frameworks. The Bank of England also provides macroeconomic scenarios that many UK entities reference when developing their forward-looking ECL assumptions.
Practical Guidance for United Kingdom
For UK entities applying the simplified approach to trade receivables under IFRS 9.5.5.15, a provision matrix based on historical loss rates adjusted for forward-looking information is the most common methodology. Historical loss data should be sourced from internal credit management records, segmented by customer type, geography, industry sector, and ageing bracket. Forward-looking adjustments should reference UK-specific macroeconomic indicators including the Bank of England base rate, UK GDP growth forecasts, unemployment projections from the Office for National Statistics (ONS), and sector-specific indicators from bodies such as the Confederation of British Industry (CBI). Post-Brexit trade dynamics, including customs delays and currency fluctuations affecting cross-border receivables with EU counterparties, should be factored into forward-looking overlays where material. Entities should document the linkage between macro-economic indicators and expected default rates, supported by historical back-testing of model performance.
Audit Expectations
The FRC Audit Quality Review (AQR) team has consistently flagged ECL as an area requiring enhanced audit attention. Common inspection findings include insufficient independent challenge of management's SICR thresholds and staging criteria, inadequate testing of the completeness and accuracy of data inputs to ECL models, limited assessment of the reasonableness of forward-looking scenarios and their probability weightings, and failure to evaluate the appropriateness of management overlays with sufficient scepticism. UK auditors are expected to engage specialists where ECL models involve complex statistical techniques and to perform retrospective reviews comparing prior-period ECL estimates with actual credit loss outcomes.
United Kingdom-Specific Considerations
UK-specific considerations for IFRS 9 ECL include the interaction between ECL provisions and distributable profits under the Companies Act 2006. ECL charges flow through profit or loss and reduce realised profits, which directly impacts distributable reserves. HMRC treats IFRS 9 ECL provisions as deductible for corporation tax purposes only to the extent that they meet the conditions in the loan relationships and derivative contracts legislation in CTA 2009. Specific provisions are generally deductible, but collective provisions based on statistical models may face additional scrutiny. The Bank of England's Prudential Regulation Authority (PRA) has issued supervisory statements relevant to banks and building societies, requiring them to ensure their ECL methodologies are robust, well-governed, and subject to independent validation. For non-financial entities, the FRC expects ECL disclosures in the annual report to align with the narrative discussion of credit risk in the strategic report and the risk management disclosures under IFRS 7.
Forward-Looking Data Sources
Common Inspection Findings
Forward-looking information not adequately incorporated — ECL models relied excessively on historical loss rates without macro-economic adjustments
SICR thresholds not sufficiently challenged — auditor accepted management's staging criteria without independent assessment of their appropriateness
Management overlays not adequately evaluated — post-model adjustments accepted without testing the underlying rationale or quantification methodology
Sensitivity analysis for ECL estimates not performed or disclosed with sufficient granularity
Retrospective back-testing of prior-period ECL estimates against actual outcomes not performed