APRA Acts on ING Australia: APS 210 Liquidity Breach Lessons

On 3 September 2026, the Australian Prudential Regulation Authority (APRA) imposed licence conditions on ING Bank Australia Limited (ING Australia), raised the bank’s minimum liquidity requirement and applied a $50 million operational risk capital add-on. The trigger was a multi-year overstatement of the bank’s Liquidity Coverage Ratio (LCR). ING Australia had been reporting an LCR of around 160 per cent, while its true ratio was substantially lower and at times fell below the 100 per cent minimum. APS 210 requires a locally incorporated LCR ADI’s AUD and all-currencies LCR to be at least 100 per cent absent a situation of financial stress; during financial stress, the standard recognises that the LCR may fall below the minimum as liquid assets are used.

ING Australia notified APRA in July 2026 that it had identified material miscalculations of its liquidity position over several years, and it has since lifted its liquidity to well above the minimum. APRA says the bank remains financially resilient and well capitalised, and points to the financial strength of the broader ING group. The action is still a supervisory marker for every other LCR ADI. The accuracy of the numbers behind an APS 210 filing, and the duty to notify APRA immediately of an actual LCR breach or once the ADI becomes aware of circumstances that may result in one, are central to this case.

Related reading: APRA’s licence conditions on Bendigo and Adelaide Bank

What APRA imposed on ING Australia

APRA applied three supervisory measures together. They address the liquidity and prudential-reporting failures identified by APRA:

• Licence conditions requiring ING Australia to commission independent reviews into the causes of its liquidity reporting failures and its broader risk management and governance, to build a remediation plan for the weaknesses identified, and to obtain independent assurance that those fixes are implemented and embedded.
• A higher minimum liquidity requirement, set above the APS 210 floor, so the bank operates prudently while it addresses the drivers of the failure.
• A $50 million operational risk capital add-on, which APRA attributes to heightened operational risk and potential broader weaknesses in the bank’s prudential reporting.

The capital add-on, the increased liquidity requirement and the licence conditions stay in place until ING Australia completes the required work to APRA’s satisfaction.

The APS 210 Liquidity Obligations This Breach Engages

Absent a situation of financial stress, APS 210 requires a locally incorporated LCR ADI to keep both its Australian dollar LCR and its all-currencies LCR at or above 100 per cent. The LCR is calculated as the stock of high-quality liquid assets divided by total net cash outflows over the next 30 calendar days under the prescribed stress scenario. During financial stress, APS 210 recognises that the LCR may fall below the minimum as liquid assets are used. A locally incorporated LCR ADI must separately maintain an NSFR of at least 100 per cent at all times.

The standard also requires an ADI to inform APRA immediately of an actual breach of its LCR requirement, or of circumstances that may result in a breach. That duty is not conditional on the ADI first finishing its own investigation once the APS 210 notification trigger has been met. APRA separately states that ING Australia notified it in July 2026 after identifying material miscalculations of its liquidity position over several years. APS 210 places ultimate responsibility for the sound and prudent management of the ADI’s liquidity risk on the board. Separately, ARS 210.0 requires all information provided under the reporting standard to be subject to processes and controls for the internal review and authorisation of that information.

The accuracy question bites here. A reported LCR of around 160 per cent that was in truth below 100 per cent at points meant the reported figure did not reflect the bank’s true liquidity position. APRA’s Deputy Chair, Therese McCarthy Hockey, said the episode raises fundamental questions about the effectiveness of the bank’s risk management and controls when it cannot accurately measure one of its most important financial safeguards.

LCR ADIs and MLH ADIs are a different population

APS 210 does not classify locally incorporated ADIs by a stated size threshold. APRA determines whether each locally incorporated ADI is an LCR ADI or an MLH ADI, while a foreign ADI is an LCR ADI unless APRA determines that it is an MLH ADI. Separately, the RBA’s April 2025 Financial Stability Review, using data through December 2024, stated that the LCR applied to the 13 largest and most complex banks in its bank dataset, with all other banks subject to the MLH regime. ING Australia, with more than 2 million customers and assets over $100 billion, sits firmly in the LCR population. The mechanics of how ADIs source and report their liquidity are set out in our note on how Australian ADIs manage liquidity and report it to APRA.

The distinction matters when reading across from this case. An MLH ADI does not calculate an LCR, so a 30-day-outflow miscalculation of this exact kind cannot arise for it in the same form. The governance point behind the action, that the number a bank files must reflect what the bank actually holds, is regime-agnostic. For a refresher on how the two Basel liquidity ratios are constructed, see our explainer on how the LCR and NSFR are built.

Where the reporting exposure sits

The LCR figures APRA supervises are drawn from Reporting Standard ARS 210.0 Liquidity, through forms ARF 210.1A, which collects the all-currencies LCR, and ARF 210.1B, which collects the AUD-only LCR. A miscalculation that overstated the ratio for several years points to a failure in the controls supporting liquidity measurement and prudential reporting. APRA’s 3 September 2026 release does not identify whether the error arose from cash-flow assumptions, HQLA classification, mappings, reconciliations or another specific control.

For an ADI using manually maintained mappings between a liquidity engine and the ARF 210.1 templates, those mappings are one control point that should be reconciled and independently reviewed. APRA’s release does not state that manual mappings caused ING Australia’s breach. A high reported LCR is only as reliable as the calculation and the assurance chain behind it. Two points cut against a reassuring reading of the outcome. Being financially resilient did not spare ING Australia the licence conditions and the capital add-on, because APRA treated the measurement failure itself as serious even though the corrected liquidity position was sound. And APS 210 has not changed here; the standard commenced on 1 July 2025, and this is a supervisory response to one ADI while the framework for everyone else stands.

Frequently Asked Questions

Does this action change APS 210 or the ARS 210.0 reporting forms?

No. APS 210 Liquidity, which commenced on 1 July 2025, and Reporting Standard ARS 210.0 are unchanged by this case. The licence conditions, higher liquidity requirement and capital add-on are institution-specific supervisory measures applied to ING Australia, not framework amendments that other ADIs must implement.

Is an MLH ADI affected by an LCR-driven action like this?

An MLH ADI does not calculate or report an LCR, so the specific overstatement here cannot occur in the same way. What carries across is the expectation that the liquidity data an ADI submits reflects its true position, and that the board can stand behind the controls that produce it. The reporting instrument differs by regime; the integrity requirement does not.

When does APS 210 require an ADI to tell APRA about a liquidity breach?

APS 210 requires an ADI to inform APRA immediately of an actual breach of its LCR requirement, or as soon as it becomes aware of circumstances that may result in a breach. The trigger is an actual LCR breach or awareness of circumstances that may result in a breach. A suspected miscalculation should therefore be assessed promptly against that trigger; APS 210 does not state that every unquantified calculation concern must be notified immediately.

Related Articles

• APRA Licence Conditions on Bendigo and Adelaide Bank: another recent APRA licence-condition action tied to risk management and governance weaknesses.
• RBA Ample Reserves and ADI Liquidity: how Australian banks source Exchange Settlement liquidity and how that feeds APRA reporting.
• Liquidity Reporting: LCR, NSFR and ALMM Explained: the construction of the LCR and NSFR and the data behind each ratio.
• APRA, Accountability and Bendigo: how APRA links governance failures to accountability obligations for banks.
• ICAAP and ILAAP: how internal capital and liquidity adequacy assessments frame a supervisor’s view of a bank.

Key Takeaways

• Absent a situation of financial stress, APS 210 requires a locally incorporated LCR ADI to keep both its AUD and all-currencies LCR at or above 100 per cent; ING Australia’s true LCR fell below 100 per cent at times while it reported around 160 per cent.
• APS 210 requires an ADI to notify APRA immediately of an actual LCR breach or circumstances that may cause one; ING Australia self-identified and notified APRA in July 2026.
• APRA’s response combined licence conditions (independent reviews, a remediation plan, independent assurance), a higher minimum liquidity requirement, and a $50 million operational risk capital add-on.
• The measures remain in place until ING Australia completes the required work to APRA’s satisfaction; APRA still regards the bank as financially resilient and well capitalised.
• LCR is reported to APRA under ARS 210.0 via forms ARF 210.1A (all-currencies LCR) and ARF 210.1B (AUD-only LCR); the controls and assurance behind those figures are the point of exposure.

Sources and References

• APRA, APRA takes action to address material liquidity breaches by ING Australia (media release, 3 September 2026).
• APRA, Prudential Standard APS 210 Liquidity (commenced 1 July 2025; Banking (prudential standard) determination No. 3 of 2025).
• APRA, Reporting Standard ARS 210.0 Liquidity (ARF 210.1A and ARF 210.1B).
• APRA, Prudential Practice Guide APG 210 Liquidity.
• Reserve Bank of Australia, Financial Stability Review, April 2025 (LCR and MLH regimes; data through December 2024).

What ING’s LCR Breach Puts on Every ADI’s Reporting Desk

The measures on ING Australia are institution-specific, but the weakness they respond to is common across LCR ADIs. For any LCR ADI, the practical response is to trace the assurance chain from the liquidity model through to the ARF 210.1A and ARF 210.1B returns, confirm who independently challenges the ratio before it is filed, and check that the APS 210 duty to notify APRA of a prospective breach is wired into that process rather than left to the end of an internal review.

Disclaimer: The information on RegReportingDesk.com is for educational and informational purposes only. It does not constitute legal, regulatory, tax, or compliance advice. Always consult your compliance officer, legal counsel, or the relevant supervisory authority for guidance specific to your institution.