Gazettal of revised SPM module CA-B-2 “Systemically Important Banks”

For compliance and regulatory affairs teams at SIBs and their groups, the immediate priority is to obtain the revised module, compare it against the prior version and map any changed expectations to existing policies, controls and governance arrangements. The update is likely to be most relevant to board and senior management oversight, risk management, capital and liquidity resilience, recovery and resolution preparedness, and supervisory engagement. Firms should treat this as a trigger for a focused gap assessment rather than a purely administrative publication: document any policy or process changes, assign owners and escalate material findings to the relevant committees.

Non-SIB banks should also review the module to understand whether designation criteria, group dependencies or contagion considerations could affect them indirectly. Business risks include heightened supervisory scrutiny and potential remediation costs if changes are not promptly operationalised; opportunities include strengthening resilience frameworks, evidencing robust governance and using the update to reinforce credibility with counterparties and regulators. Compliance teams should confirm implementation timing with the HKMA where not explicit, maintain a traceable change log and ensure board reporting reflects the revised expectations.