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IFRS 9 High divergence

Financial Instruments

Treatment under IFRS

Classification by business model and contractual cash-flow characteristics into FVTPL, FVOCI or amortised cost. An expected-credit-loss (ECL) model is used for impairment.

  • Categories: amortised cost, FVOCI (with/without recycling) and FVTPL.
  • ECL model: a three-stage approach – a 12-month ECL is recognised already at initial recognition.
  • Hedge accounting: a strict framework with effectiveness requirements.
  • Derivatives: always measured at fair value (even without a hedging relationship).

Treatment under German GAAP (HGB)

§ 253 HGB§ 255 HGB§ 340e HGB

German GAAP distinguishes between non-current and current assets. Measurement is at (amortised) cost under the lower-of-cost-or-market principle. There is no ECL model; allowances are recognised only when a concrete default risk exists.

  • § 253 (1) HGB: cost is the measurement ceiling.
  • § 253 (3)/(4) HGB: the lower-of-cost-or-market principle, depending on classification as a non-current or current asset.
  • § 340e (3) HGB: trading-book financial instruments of credit institutions are measured at fair value less a risk discount.
  • § 254 HGB: the formation of valuation units (the German-GAAP form of hedge accounting).

Key differences

  • No ECL model; HGB recognises an allowance only on an actual default or an identifiable risk.
  • No fair-value measurement of debt instruments held as non-current assets (except the trading book of credit institutions).
  • Derivatives, as pending transactions, are generally not recognised under HGB; where their fair value is negative, a provision for onerous contracts must be recognised.
  • Hedge accounting under HGB uses valuation units (§ 254 HGB) and is less formalised than under IFRS 9.

Example

Example – a €1,000,000 loan whose default risk rises over three years: under the ECL model IFRS recognises an allowance already in year 1 (12-month ECL €5,000), increases it to €50,000 (lifetime ECL) and to €200,000 on default. HGB recognises the loss only once a concrete default risk is identifiable (here €200,000 in year 3). The total expense is the same; only the timing differs.

Worked example

Assumptions: A loan of €1,000,000 (3-year term) is fully recoverable at origination. Its credit risk deteriorates: year 1 performing (IFRS stage 1), year 2 significantly increased credit risk (stage 2), year 3 default (stage 3). Expected losses are €5,000 (stage 1, 12-month ECL), €50,000 (stage 2, lifetime ECL) and €200,000 (stage 3, incurred loss). Assumption for HGB: a concretely identifiable default risk (the condition for a specific write-down) only exists in year 3. All amounts in euros.

Step 1 – The ECL model (IFRS) vs the lower-of-cost-or-market principle (HGB)

IFRS 9 requires a loss allowance equal to the expected loss already on initial recognition (12-month ECL) and increases it to the lifetime ECL as risk rises. HGB recognises a specific write-down only once a concrete default risk is identifiable (§ 253 (3)/(4) HGB, lower-of-cost-or-market) – it has no forward-looking day-one loss on a fully recoverable loan.

Step 2 – Loss allowance over time (balance)

YearIFRS stageIFRS allowanceHGB allowance
1Stage 1 (12-month ECL)5,0000
2Stage 2 (lifetime ECL)50,0000
3Stage 3 (default)200,000200,000

Step 3 – P&L effect per year (change in allowance)

YearIFRS expenseHGB expense
15,0000
245,0000
3150,000200,000
Total200,000200,000

The total loss is identical (€200,000); IFRS spreads it forward over the term, whereas HGB recognises it only once the risk is concretely identifiable.

Step 4 – Journal entries

IFRS – year 1 (recognition of the 12-month ECL):

AccountDebitCredit
Loan-loss expense (P&L)5,000
Loss allowance on the loan5,000

HGB – year 3 (specific write-down on identifiable default):

AccountDebitCredit
Write-down of receivables (P&L)200,000
Allowance on the receivable200,000

Key takeaway

IFRS 9 is forward-looking: even a fully recoverable loan carries an expected-loss allowance (12-month ECL), extended to the lifetime ECL as risk rises. HGB is event-driven: a specific write-down arises only once a concrete default risk is identifiable. For latent risk in the receivables portfolio HGB also permits a general (portfolio) allowance – but this is not a full equivalent of the ECL model. The cumulative expense is the same under both systems (€200,000); the difference lies in the timing of recognition.

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