The German Banking Industry Committee (Die Deutsche Kreditwirtschaft – DK) welcomes the “Post-implementation Review IFRS 9 Financial Instruments Impairment” and notes that the implementation of the impairment rules of IFRS 9 has been a very high effort for the banks. In many banks, IFRS 9 was the largest project ever for several years.

However, the principles based IFRS 9 rules have proven their worth in practice. The expected credit loss (ECL) model under IFRS 9 generally leads to an earlier recognition of impairments than the incurred credit loss model under IAS 39. DK does not currently see any significant need for adjustment.