Initial guidance for existing deposit takers on relicensing under the Deposit Takers Act 2023

Version 14 September 2026 – initial guidance 3 Guidance Note version history 14 September 2026 Published alongside the near-final relicensing questions released on 14 September 2026.

Version 14 September 2026 – initial guidance 4 Introduction The Reserve Bank of New Zealand – Te Pūtea Matua (the Reserve Bank, RBNZ, we) is undertaking a multi-year programme of work to implement the Deposit Takers Act 2023 (the DTA). This guidance is for existing deposit takers who intend to apply for a licence under the DTA – also referred to as relicensing in this guidance. The relicensing period will commence on 1 June 2027 and run for 18 months until the DTA commences on 1 December 2028. The relicensing process focuses on a deposit taker’s ability to comply with the core standards applicable to its proportionality group. Key milestones for licensing existing deposit takers under the DTA Timing Key milestone September 2026 Publication Draft relicensing questions and guidance May 2027 Publication Finalised relicensing questions and guidance By 31 May 2027 DTA Standards issued (all but crisis preparedness). 1 June 2027 Relicensing applications open 3 September 2027 Submission deadline – existing stand-alone branches 29 October 2027 Submission deadline – existing Group 3 deposit takers 2 June 2028 Submission deadline – existing Group 1 deposit takers and their branch counterparts 28 July 2028 Submission deadline – existing Group 2 deposit takers and their branch counterparts 1 December 2028 All DTA standards commence 1 December 2028 (except the Crisis Preparedness Standard and the Continuity of Access to Deposits (CoAD) Standard) Refer to the RBNZ website for further information on the DTA and timeline. Deposit Takers Act - Reserve Bank of New Zealand - Te Pūtea Matua

Version 14 September 2026 – initial guidance 5 Contents Introduction ___________________________________________________________________________________ 4 Key milestones for licensing existing deposit takers under the DTA __________________________ 4

1. Use of the guidance ______________________________________________________________________ 6
   Application_________________________________________________________________________________ 6 Purpose ____________________________________________________________________________________ 6 Terminology _______________________________________________________________________________ 6 Further versions ____________________________________________________________________________ 6
2. Completing your relicensing application ________________________________________________ 7
3. Relicensing questions_____________________________________________________________________ 7
   Types of questions _________________________________________________________________________ 8 Documentation_____________________________________________________________________________ 9
4. Negative assurance questions – Capital and Disclosure Statements Standards _______ 10
   Change analysis – Disclosure Statements Standard_________________________________________ 10 Change analysis – Capital Standard________________________________________________________ 13

Version 14 September 2026 – initial guidance 6

1. Use of the guidance
   This document provides guidance only and is not a substitute for obtaining independent advice. Application This guidance is intended to support registered banks and licensed non-bank deposit takers to complete a relicensing application under the DTA. This guidance is not applicable to new deposit takers applying under the DTA. Purpose This guidance is designed to be read alongside the near-final relicensing questions. Its purpose is to help applicants understand how to answer relicensing questions and the information we are looking for within an application, and to promote complete, relevant and well-structured responses. The guidance explains what applicants should consider addressing and the level of detail that is generally expected of a relicensing application. This document is intended to be practical and informative. It does not prescribe a single approach to answering the application questions, nor does it provide model answers. Rather, it is designed to help applicants exercise judgement when preparing responses and to understand the factors that may be relevant to demonstrating compliance with relicensing requirements. Applicants are expected to consider their own circumstances when responding to the questions. The nature, scale and complexity of the information provided should be proportionate to the size, business model, risk profile and organisational structure of the deposit taker. Applicants should also take into account their current stage of preparedness for transitioning to compliance with the DTA and relevant prudential standards. Responses should therefore reflect the applicant’s own assessment of its arrangements, plans and capabilities. The Reserve Bank will expand on this guidance in future updates. We will notify deposit takers when updates occur. Terminology Where this document uses words and phrases that are also used in the DTA, those words and phrases have the same meaning as set out in the DTA (unless otherwise specified). Further versions We will keep the guidance under review and may issue updates where they would assist applicants. Examples of responses to questions may also be published to support applicants.

Version 14 September 2026 – initial guidance 7
2. Completing your relicensing application
A set of ‘core’ standards will be used as the criteria to determine the eligibility of existing banks and non-bank deposit takers for relicensing under the DTA. These are the standards that will apply to each group for relicensing:

• Group 1: Capital, Internal Models, Liquidity, DCS, Disclosure Statements and Reporting (6
  standards)
• Group 2: Capital, Liquidity, DCS, Disclosure Statements and Reporting (5 standards)
• Group 3: Capital, Liquidity, DCS and Reporting (4 standards)
• Branches: Liquidity, Disclosure Statements and Reporting (3 standards)
  We will ask questions to assess an applicant’s ability to comply with the core standards from 1 December 2028. Our assessment will focus on the key differences between the current legislative regime and the requirements under the DTA, and on how the applicant plans to transition to the new regime. If you describe future-state arrangements or actions that are still to be completed, your responses should also explain how implementation will be managed and monitored. You should consider outlining the controls, governance, oversight and reporting arrangements that will support delivery of the proposed outcomes, as well as any significant risks, dependencies or assumptions. Where relevant, you should also describe how you will assess whether new or enhanced arrangements are operating as intended and what actions may be taken if implementation milestones are not achieved or if controls are not performing effectively. This information helps provide assurance that proposed arrangements are achievable, sustainable and appropriately managed. We may come back to you during our assessment with further questions. Where to find licensing questions Review the near-final relicensing questions for existing deposit takers on the RBNZ website. Visit the dedicated DTA section of our website to find other useful information.

3. Relicensing questions
   We have focused the more substantive relicensing questions on requirements that are new or changing from the current prudential regime. Generally, we will ask you four types of questions:

• How will you comply with a given requirement?
• When will you be able to implement this requirement?
• Confirm you will comply with a requirement.
• Are there any other issues you foresee that will impact your ability to comply with a
  requirement/standard?

Version 14 September 2026 – initial guidance 8 These types of questions reflect the transitional nature of the relicensing process and that the core standards will not be in force when the relicensing period starts. We recognise that you may still be implementing the prudential requirements set out in the core standards when you submit your application. This means we are not expecting to see evidence that you already meet the requirements when you submit your application – rather, we will focus on understanding your preparedness and assess your ability to meet the requirements at that time. Types of questions This section explains what types of questions we will ask in the online relicensing application. ‘How’ questions When we ask a how question, we are looking to establish your understanding of the prudential requirements, and how your proposed solutions will meet those requirements. We expect a comprehensive description of what you will put in place and the supporting processes. Although you will not need to provide documentation with the application, we will want to understand what documents you have created, such as written policies, templates, data-generation procedures and registers. We suggest you closely review the relevant section of the core standard and ensure all elements are addressed in your answer. ‘When’ questions When we ask a when question, we are looking to establish that the solution you have outlined can be implemented within an appropriate timeframe. You must be able to demonstrate that you have the ability to comply with the core standards from 1 December 2028. We will be assessing whether there is a credible pathway to compliance. If you are already compliant with the future requirement, a short answer will suffice. However, in most cases, we expect further work will be needed between the date you submit your application and the date the core standards come into force. In assessing when questions, we want to understand four key areas – work already undertaken, work still to come, your available resourcing, and any risks you foresee. The table below provides guidance on the information you should consider including in your response to this type of question. Area Prompts to consider Work undertaken to date

• What progress has been made to date? What key milestones have you
  already met, and were these met on schedule?
  Work still to come
• How far through the implementation are you?
• When precisely will your organisation comply with the requirement?
• What milestones still need to be completed?
• Are these steps substantive or procedural?
  Resourcing • What resourcing have you allocated?
• Are these resources internal or have you engaged external support?
• Are you satisfied with the skills and expertise available to the project?

Version 14 September 2026 – initial guidance 9 Area Prompts to consider

• If your implementation faces delays, could you bolster your resourcing to
  cover the deficit?
  Risks present • Are there any material risks you foresee which may affect the implementation of your proposed solution? What mitigants are in place?
• How will you deal with risks that arise during the relicensing period?
• What controls will you have in place to ensure you meet these
  requirements? How will you monitor and measure the effectiveness of these controls? If a control proves to be ineffective, what would happen and who is accountable? ‘Confirm’ questions Where there are only minor changes between current prudential requirements and equivalent requirements in the relevant core standard, we ask ‘confirm’ questions. These questions require a yes or no answer, and you are not required to provide detailed information on your implementation plan as part of your initial application. However, we may request further information during our assessment if we consider it necessary. A ‘no’ response will not, by itself, impact your application negatively. You will be asked to provide an explanation for your response. You may also be required to answer follow-up questions during the assessment phase. Where we ask if you have approved documents, arrangements, or processes in place, our expectation is that these have been formally reviewed and approved, in accordance with your governance structure. If this is not the case, we would expect an explanation as to when that would occur. ‘Negative assurance’ questions For each core standard, you will be asked to identify any issues that may impact your ability to comply with that standard. This includes the ability to comply with obligations in that core standard that are not the subject of a specific licensing question. If you have identified any issues, we expect you to provide a comprehensive answer identifying the nature of the issue, the risk it presents, what mitigants are in place, the degree of impact, your plan to reach compliance, and what resourcing you have allocated to address the issue – similar to the ‘how’ and ‘when’ questions. Documentation You are not required to provide supporting documentation as part of your application. However, you should be able to identify any relevant documentation and to describe how it applies or is relevant as part of your responses. If we consider it necessary, we may request further clarification or documentation during our assessment, but this will be by exception.

Version 14 September 2026 – initial guidance 10
4. Negative assurance questions – Capital and Disclosure
Statements Standards
During the development of the Disclosure Statements Standard and the Capital Standard, a significant number of minor or technical changes were identified compared with the current legislative frameworks. Given the large number of such changes within these two standards, we are not asking for detailed information on applicants’ ability to comply with each individual obligation. Instead, an additional ‘negative assurance’ question is included for applicants to whom these standards apply. This means applicants are asked to identify areas where they anticipate issues or challenges achieving compliance with the requirements within these clauses. This approach reduces the information required and enables responses to focus on areas of concern. The table below contains the applicable clauses and a very high level summary of the changes between existing prudential requirements and the equivalent requirement in the relevant core standard. These changes are the subject of the relevant ‘negative assurance’ questions. Please note, entities must review each clause themselves and may not rely on the high-level summary produced, when giving their negative assurance. In the table below, ‘Group’ refers to proportionality group and ‘Clause’ refers to the clause number in the published exposure draft of the relevant core standard. Change analysis – Disclosure Statements Standard Group Clause Change analysis 1, 2, Branches 7 – How deposit taker must publish disclosure statement Clause 7 largely retains the existing publication requirements with some minor differences (e.g. it does not carry forward the ability for the Reserve Bank to permit late publication of a half-year disclosure statement where reasonable grounds exist). Subclause 7(d) also introduces an additional publication requirement. 1, 2, Branches 10 - Year-end disclosure statement must be accompanied by financial statements This clause clarifies that the accompanying financial statements are those of the deposit taker, rather than only those of the registered bank's banking group. 1, 2, Branches 11 - Mid-year disclosure statement must be accompanied by interim financial statements Subclauses 11(2) and 11(3) introduce additional requirements while retaining the substantive obligation to accompany the disclosure statement with interim financial statements. 1, 2, Branches 16 – Availability of information on financial strength dashboard Clause 16 introduces a new requirement to include a prescribed statement about the (Bank) Financial Strength Dashboard in disclosure statements.

Version 14 September 2026 – initial guidance 11 Group Clause Change analysis 1, 2, Branches 23 – Contact information Subclauses 23(2)(a)(ii) and 23(2)(b)(ii) introduce a requirement to disclose an email address for communication with directors or, in the case of branches, the New Zealand Chief Executive. 1, 2, Branches 24 – Details of certain holding entities This clause extends the information required to be disclosed at mid￾year by requiring disclosure of information that is currently only required in year-end disclosure statements. 1, 2, Branches 28 – Audit, risk, and remuneration committees Clause 28 introduces new disclosure requirements relating to risk and remuneration committees. Existing disclosure requirements are limited to board audit committees. 1, 2, Branches 31 – Credit rating Clause 31 does not expressly require disclosure of the type of credit rating and expands the information required in mid-year disclosures. Subclause 31(2)(c) also introduces additional disclosure requirements relating to credit watch warnings. Branches 34 – Proceedings or arbitrations This clause extends the disclosure requirement to mid-year disclosure statements. 1, 2 35 – Priority of creditors' claims Clause 35 introduces more prescriptive disclosure requirements regarding the priority of creditors' claims. Subclause 35(4) also extends this disclosure to mid-year reporting. 1, 2 38 – Information about depositor compensation scheme Clause 38 introduces a new requirement to include a prescribed statement about the Depositor Compensation Scheme in disclosure statements. 1, 2, Branches 43 – Capital ratios Clause 43 removes disclosure of the Common Equity Tier 1 capital ratio and replaces existing prudential capital buffer and trigger terminology with combined ratio and distribution restriction threshold terminology. 1, 2, Branches 45 – Capital ratio information about supervised overseas holding entities and their subsidiaries This clause broadens the scope of the requirement by referring to supervised overseas holding entities rather than only ultimate parent banks. 1, 2, Branches 55 – Credit valuation adjustment (CVA) capital charge Subclause 55(1)(c) introduces a requirement to disclose key judgements and assumptions used in calculating the CVA capital charge. 1 65 – Lending subject to standardised approach off-balance￾sheet exposures Clause 65 introduces the disclosure of a memo item in respect of any undrawn commitments to the New Zealand Business Growth Fund. 1 70 – Credit risk mitigation Subclauses 70(2)(d) to (g) introduce more granular exposure classes for the purposes of the disclosure.

Version 14 September 2026 – initial guidance 12 Group Clause Change analysis 1, 2, Branches 77 – Operational risk Subclause 77(2)(c) introduces a requirement to disclose the amount of each component of the business indicator for each of the previous three financial years. 1, 2, Branches 78 – Market risk end￾period capital charges Subclause 78(2) requires separate disclosure of banking book and, where applicable, trading book capital charges. Subclause 78(2)(d) also introduces disclosure relating to commodity risk. 1, 2, Branches 86 – Exposure to non￾consolidated insurance business Subclause 86(4) introduces a requirement to, in a mid-year disclosure statement, disclose any material change since the most recent year-end disclosure statement. 1, 2 92 – Mismatch ratio and core funding ratio Clause 92 expands disclosure requirements by requiring disclosure of updated regulatory liquidity metrics, including the highest and lowest values during the reporting period. The clause also replaces the one-week and three-month mismatch ratios with a single 30-day mismatch ratio. 1, 2, Branches 111 – Large exposures Clause 111 applies the disclosure requirement to year-end disclosure statements only and replaces Common Equity Tier 1 capital with Tier 1 capital as the relevant capital measure. 1, 2, Branches 112 – Peak end-of-day total credit exposures Clause 112 applies the disclosure requirement to year-end disclosure statements only and replaces Common Equity Tier 1 capital with Tier 1 capital as the relevant capital measure. 1, 2, Branches 114 – Meaning of categories of risk Clause 114 revises the categorisation of risk by incorporating cybersecurity risk within operational risk, introducing model risk as a separate category, identifying concentration risk separately, and using market risk as a broader category. 1, 2, Branches 117 – Reviews of risk management framework Subclause 117(2) introduces an additional disclosure requirement relating to reviews of the risk management framework. 1, 2, Branches 118 – Internal audit function of deposit taker Clause 118 expands the existing disclosure requirements by introducing disclosure relating to the compliance function, reporting responsibilities, adequacy of resourcing and operational independence. 1, 2, Branches 119 – Access to holding entity disclosures Subclause 119(2)(b) introduces a requirement for New Zealand subsidiaries to explain how they have relied on the broader group's risk management strategy for their New Zealand operations. 1, 2, Branches 120 – Mid-year disclosure statement Clause 120 expands the scope of mid-year reporting by requiring disclosure of any material change to information reported under
Part 11, rather than only changes to risk management policies or risk
categories.

Version 14 September 2026 – initial guidance 13 Group Clause Change analysis 1, 2, Branches 123 – Statement of financial position Clause 123 changes the timing of certain disclosures by requiring some information that is currently reported at mid-year to be included in year-end disclosures. Subclause 123(4) also introduces an additional requirement for determining related parties. 1, 2, Branches 125 – Statement of financial performance Clause 125 changes the timing of disclosure by requiring information currently reported at mid-year to also be disclosed at year-end. 1, 2, Branches 134 – Movements in components of loss allowance Subclauses 134(5) and 134(6) introduce additional disclosure requirements relating to movements in components of loss allowance. Change analysis – Capital Standard Group Clause Change analysis 1, 2 11 - Meaning of solo basis Clause 11 introduces references to funds management activities and defines an internal RMBS SPV. 1, 2 13 - Tier 1 capital ratio Clause 13 increases the minimum Tier 1 capital ratio relative to existing requirements and introduces a new mechanism for imposing capital overlays. 1, 2 14 - Combined capital ratio Clause 14 increases the minimum combined capital ratio relative to existing requirements and introduces a new mechanism for imposing capital overlays. 1, 2 21 – Distribution restrictions relating to combined buffer ratio Clause 21 introduces revised threshold levels for distribution restrictions. 1, 2 24 - Deposit taker must have internal capital adequacy assessment process (ICAAP) Subclause 24(1)(b) introduces an explicit requirement for a deposit taker to take all practicable steps to comply with its ICAAP. 1, 2 25 - Board must approve ICAAP Clause 25 introduces an explicit requirement for board approval of the ICAAP and any amendments to it. 1, 2 26 - ICAAP must be appropriate to operations of deposit taker Clause 26 rearticulates the proportionality requirement for ICAAPs. 1, 2 29 - ICAAP must be reviewed Subclauses 29(2)(a) and 29(3) introduce more specific requirements regarding the timing of ICAAP reviews.

Version 14 September 2026 – initial guidance 14 Group Clause Change analysis 1, 2 37 - Meaning of total capital Clause 37 removes reference to CET1 and AT1 capital. 1, 2 84 – Deposit taker must notify Bank of new instrument to be used for capital requirements Subclause 84(2) makes it explicit that a capital instrument cannot be recognised for regulatory capital purposes until the notification requirement has been met. 1, 2 142 - Exposure to small and medium enterprises Clause 142 removes the concession allowing certain exposures to be treated as SME exposures where a counterparty's annual income cannot reasonably be determined. It also introduces definitions of related party, control and connected person. 1, 2 143 - Farm lending exposure Clause 143 introduces additional detail regarding the treatment of farm lending exposures, including a definition of LVR and related concepts. 1, 2 144 - Valuation policy for farm lending exposures Clause 144 revises the applicable LVR percentages used in the valuation framework for farm lending exposures. 1, 2 145 - Community housing provider Clause 145 modifies the definition of community housing provider and introduces risk weighting options for loans that are subject to a Crown guarantee. 1, 2 148 - Meaning of residential mortgage loan (RML) Clause 148 expands the definition of a residential mortgage loan through the introduction of subclauses 148(1)(b)(ii), 148(1)(b)(iii), 148(3) and 148(4). 1, 2 235 - Restrictions on including own equity and fixed assets in calculations Subclauses 235(1)(b) and 235(3) introduce additional restrictions on the treatment of own equity interests and fixed assets in regulatory capital calculations. 1, 2 237 - Calculation of capital requirement for market risk Clause 237 introduces a requirement to calculate market risk capital requirements separately for banking book and trading book exposures. 1, 2 267 - Scope of calculation Clause 267 introduces new decomposition requirements. 1, 2 270 - Scope of calculation Clause 270 introduces new decomposition requirements. 1, 2 271 - Valuation of equity instruments Subclause 271(d) introduces a requirement that an instrument be recognised under NZ IFRS 9 before it can be valued at market value.

Version 14 September 2026 – initial guidance 15 Group Clause Change analysis 1, 2 303 – Minimum requirements Clause 303 does not carry forward certain disclosure and investor acknowledgement requirements relating to affiliated insurance products. 1, 2 306 – Methods of clean transfer Clause 306 introduces an explicit definition of sub-participation.