When the IASB first released details of its game changing IFRS 9, Financial Instruments, in 2014, the most revolutionary aspect was that accounting, aside from fair value valuations, would now have a more forward looking view for expected loss calculations.

Accordingly, most financial institutions started their gap analysis as soon as possible in 2015, looking towards 2018. But the challenge, even for phase 1, seemed to be more challenging than expected.

Most banks are yet to commence with technical implementation, so the three-year period for implementation appears to be just a fraction of what is needed.