ICAAP practitioner’s guide
How to write an ICAAP the PRA takes seriously: structure, stress testing, capital planning and board challenge, from people who write them.
By Mark Dougherty, CPA (CAN)Risk Education · In-house training
In-house risk training is a course on capital, liquidity or risk management that RiskTAE designs for one firm and teaches to its board and risk committee, or its risk, finance and treasury teams. It is built on your own framework, models and regulatory history, and taught by practitioners who have done the work in front of a regulator.
Your people leave able to produce, challenge or approve what the PRA reads next: the ICAAP, the ILAAP, the recovery plan and the first capital numbers under the rules that apply from 1 January 2027.
By Mark Dougherty, CPA (CAN)Updated
Audience
One firm at a time: a bank, building society or lender the PRA regulates, and the people inside it who produce, challenge or approve its capital and liquidity work.
Boards and risk committees who approve the ICAAP, the ILAAP and the recovery plan. Capital and reporting teams facing the Basel 3.1 calculations that apply from 1 January 2027. Treasury teams who own the ILAAP. Second-line risk functions, whether a new head of risk or an operational risk team writing the ICAAP scenarios.
Firms also ask for it as bespoke risk training or corporate risk training; whatever the label, the design starts from your documents rather than a standard deck. Training providers commission the same courses from Risk Education as white-label training, and directors have their own page at board risk training.
Sources: Bank of England, PS1/26 Implementation of Basel 3.1: final rules, 20 January 2026, paragraph 1.23; PRA Rulebook, ILAA Part, rule 13.3, and Recovery Plans Part, rule 5.2.
Programmes
Five programmes, each cut to the people in the room and tied to the rules it teaches.
| Programme | Built for | What they learn, and the rules it rests on |
|---|---|---|
| Board and risk committee | Directors, NEDs and the risk committee | The capital stack, the ICAAP and ILAAP as documents to approve, and a measurable risk appetite the board owns. SS5/16; SS31/15. |
| Basel 3.1 | Capital, prudential risk and reporting teams | The revised standardised approaches, the output floor from 60% in 2027 to 72.5% from 1 January 2030, and the returns from 1 January 2027; for small domestic deposit takers, the SDDT capital regime and its Single Capital Buffer instead. PS1/26; PS4/26. |
| The ICAAP | Its authors and the executives who sign it | Pillar 2A and Pillar 2B, stress and reverse stress testing, operational risk scenarios, and the step-in risk data items that firms outside the SDDT regime file with the ICAAP. SS31/15; Step-in Risk Part. |
| The ILAAP and liquidity | Treasury, finance and risk | The overall liquidity adequacy rule, an LCR of at least 100%, the survival period your own risk appetite sets, and a contingency plan tested at least annually. ILAA Part; SS24/15. |
| Recovery planning | Plan owners, treasury and the board | Recovery options, indicators calibrated against the buffers, recovery capacity in CET1, leverage ratio and LCR percentage points, and the fire drill the board oversees. Recovery Plans Part; SS9/17. |
Sources: PRA SS5/16, July 2018; SS31/15, paragraph 5.10; PS1/26 and PS4/26, 20 January 2026; PS5/25, 22 April 2025; SS24/15, January 2026; SS9/17, March 2026.
ICAAP and ILAAP training
Yes, as in-house workshops for the people who write the ICAAP and ILAAP and the directors who approve them. They run as a two-hour board briefing, a one-day course or a two-day workshop in which the team works through its own draft. The content covers Pillar 2A and Pillar 2B, stress and reverse stress testing and, for liquidity, the overall liquidity adequacy rule, the LCR and the contingency plan, taught to SS31/15 and SS24/15.
Sources: PRA SS31/15 The ICAAP and the SREP; PRA SS24/15 The PRA’s approach to supervising liquidity and funding risks.
Design and faculty
It starts with a 30-minute scoping call about who will be in the room and what they must be able to do afterwards. We then propose a course outline, session by session, with the rule or supervisory statement each session rests on.
The case material is yours. Your last ICAAP and ILAAP, your recovery plan and the letters that came back from the PRA become the exercises, and where you provide your own numbers the exercises run on them: a mortgage book risk-weighted under the new rules, or financial statements turned into a Business Indicator. Because the same firm writes ICAAPs through Risk Advisory and builds the RisKIT models, a live model can show what one changed assumption does to the CET1 ratio, and training can follow an advisory engagement as its handover.
Faculty come from our bench: former chief risk officers and heads of risk, former regulators and interim executives, and model and quant specialists, alongside professional trainers. The practice is led by Mark Dougherty, CPA (CAN), a Canadian Chartered Professional Accountant with more than 20 years in risk management who contributes risk management lectures to the University of Cambridge’s Banking Executive Programme.
Formats
We design to three lengths: a two-hour board briefing, a one-day course or a two-day workshop. A briefing fits inside a scheduled board meeting; a one-day course suits a team learning one regime, such as Basel 3.1 or the ILAAP; a two-day workshop suits a team that will write a document and works through its own draft in full.
Delivery is on site, online or a mix, and we have taught worldwide, including the UK, the Middle East, Africa and South Asia. A programme can run as one event or as a series timed to the ICAAP cycle. There are no public dates or open-enrolment courses; the Basel 3.1 course shows what a programme looks like in full.
Outcome
The documents get better, and the people who own them can defend them.
Sources: PRA PS9/24, 12 September 2024, paragraph 6.2; SS24/15, January 2026, paragraph 2.10; SS9/17, March 2026, paragraphs 2.72 and 2.73.
Failure points
Sources: PRA SS24/15, January 2026, paragraph 2.40A; PRA Rulebook, Fitness and Propriety Part, rule 2.6; PS12/26, 22 April 2026, paragraphs 2.20 and 2.92.
FAQ
Bespoke. Every programme starts from your framework, models and regulatory history, the exercises use your numbers where you provide them, and the outline comes after the scoping call, not before it.
Yes, usually in sequence: a briefing for the board on the questions to ask, then a workshop for the team that will answer them, both built on the same documents.
No. We make no claim to accreditation, CPD recognition or a qualification. Keep your own record of attendance for the firm’s training and fitness and propriety files.
Insights
How to write an ICAAP the PRA takes seriously: structure, stress testing, capital planning and board challenge, from people who write them.
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Tell us who the audience is and what they need to be able to do afterwards, and we will propose a course outline.
Tell us who the audience is and what they need, and we will propose a course outline.
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