Forward-Looking Credit Loss Recognition and Banks' Internal Risk Models: Timeliness, Reporting Bias, and Lending Effects

Jannis Bischof, Rainer Haselmann, Frederik Kohl and Oliver Schlueter

No 48, LawFin Working Paper Series from Goethe University, Center for Advanced Studies on the Foundations of Law and Finance (LawFin)

Abstract: The global adoption of IFRS 9 requires banks to recognize loan loss provisions based on forward-looking credit loss estimates. While these rules enhance the timeliness of loss recognition, they also expand the scope for managerial discretion in loss estimation. Using supervisory data on German banks' internal rating models, we examine how banks respond to these countervailing incentives. Relative to unaffected banks, IFRS 9 adopters update their internal credit risk estimates more frequently, consistent with a general improvement in the timeliness of loss recognition, yet assign systematically more favorable internal ratings to otherwise identical borrowers. A lower precision of these ratings accompanies this pattern, consistent with the strategic use of increased re- porting discretion outweighing the greater timeliness of the estimates. The implications for bank lending are twofold. First, to counter the increased cost of high-risk lending, banks curtail credit to borrowers most likely to experience internal rating downgrades that would trigger additional provisioning in future periods, with these lending changes extending broadly across the non-investment-grade segment and indicating a general portfolio shift toward lower credit risk. Second, lending changes cluster around seem- ingly arbitrary provisioning thresholds where expected credit losses are systematically underreported, suggesting that expanded reporting discretion distorts lending in a way that optimizes model input rather than portfolio risk.

Date: 2026, Revised 2026
New Economics Papers: this item is included in nep-acc, nep-law and nep-rmg
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