A provisioning calculation that is correct but undocumented is not auditable. A provisioning calculation that is documented but not traceable to the source data is not defensible. The Provisioning AI computes the required provision for every NPL account — following CBUAE / SAMA classification rules for regulatory reporting and IFRS 9 ECL for the accounting provision — and generates a full audit trail linking every provision figure to the classification, the outstanding balance, the security value, and the DPD count that determined it.
The two provisioning frameworks — and why both must be computed
GCC finance companies are subject to two parallel provisioning requirements that produce different provision amounts and serve different purposes. CBUAE / SAMA classification and provisioning circulars set supervisory categories and floors — while IFRS 9 ECL drives the accounting provision using lifetime loss estimates rather than India's IRACP-style fixed rate schedule. The accounting provision, computed under IFRS 9 ECL methodology, is the provision required for financial reporting purposes — based on the probability of default (PD), exposure at default (EAD), and loss given default (LGD) for each account.
The two amounts frequently differ. Where the regulatory provision exceeds the IFRS 9 ECL provision, the institution must use the higher regulatory amount. Where the ECL provision exceeds the regulatory amount (as it often does for Stage 2 accounts — assets not yet NPL but showing significant credit deterioration), the ECL provision drives the reported figure. The Provisioning AI computes both simultaneously, flags the higher amount as the required provision, and documents the reason for the differential.
"Two provisioning frameworks. Two different amounts. One has to win. The Provisioning AI computes both, identifies which is higher, and records why — for every account, every quarter."
Provision calculations: three accounts worked through in full
Provision Calculation Workings — Nov 14, 2025 Quarter-End
Three accounts · Full Central Bank Loan Classification Norms + IFRS 9 ECL calculation shown · Audit-ready
Account 1 — LA-2024-4821 · Sub-Standard · Rajan Textiles
SME Term Loan — Unsecured · Outstanding AED28.4 hundred thousand · DPD: 91 days
1Outstanding balance (principal + accrued interest)AED28,40,000
2Security / collateral valueAED0 (unsecured loan)
3Central Bank Loan Classification Norms regulatory rate: Sub-Standard, unsecured15.00%
4Central Bank Loan Classification Norms regulatory provision (Step 1 × Step 3)AED4,26,000
5ECL provision (PD 14.2% × EAD AED28.4L × LGD 82%)AED3,31,300
6Higher of regulatory / ECL provisionAED4,26,000 (regulatory higher)
Required provision
AED4,26,000
Basis
Central Bank Loan Classification Norms Sub-Standard 15% · Unsecured
AUDIT: Account classified Sub-Standard on Nov 14, 2025 00:04:22 (DPD 91, first overdue Aug 14, 2025). Provision raised from AED0 (Standard 0.40% general provision of AED11,360) to AED4,26,000. Change: +AED4,14,640. CBS updated 00:04:23. Authorisation: Provisioning AI system rule PR-SUBST-001.
Account 2 — LA-2023-2241 · Doubtful D1 · Kavitha Construction
LAP (Loan Against Property) — Secured · Outstanding AED84.2 hundred thousand · DPD: 458 days
1Outstanding balance (principal + accrued interest)AED84,20,000
2Security value (current forced-sale valuation)AED1,12,00,000 (Dubai commercial property)
3Secured portion (min of outstanding and security value)AED84,20,000 (fully secured)
4Unsecured portion (outstanding minus secured)AED0 (fully secured)
5Central Bank Loan Classification Norms rate: Doubtful D1, secured portion25.00%
6Central Bank Loan Classification Norms regulatory provision (secured × 25% + unsecured × 100%)AED21,05,000
7ECL provision (PD 38.4% × EAD AED84.2L × LGD 34%)AED11,01,700
8Higher of regulatory / ECL provisionAED21,05,000 (regulatory higher)
Required provision
AED21,05,000
Prior provision (Sub-Standard)
AED12,63,000 (15% Sub-Std)
AUDIT: Reclassified from Sub-Standard to Doubtful D1 on Nov 14, 2025 00:04:22 (DPD 458, crossed 456-day D1 threshold). Provision increased from AED12,63,000 to AED21,05,000. Incremental provision: +AED8,42,000. CBS updated 00:04:23. Security value refreshed from last approved valuation report dated Oct 12, 2025 (within 6-month validity). Authorisation: Provisioning AI system rule PR-D1-SEC-001.
Account 3 — LA-2022-0884 · Doubtful D2 · Bharat Agro Industries
SME Term Loan — Partially Secured · Outstanding AED61.8 hundred thousand · DPD: 821 days
1Outstanding balanceAED61,80,000
2Security value (agricultural equipment — distressed)AED18,50,000 (distressed forced-sale valuation)
3Secured portionAED18,50,000
4Unsecured portion (outstanding minus secured)AED43,30,000
5Central Bank Loan Classification Norms rate: Doubtful D2, secured portion40.00%
6Central Bank Loan Classification Norms rate: Doubtful D2, unsecured portion100.00%
7Central Bank Loan Classification Norms provision (AED18.5L × 40%) + (AED43.3L × 100%)AED7,40,000 + AED43,30,000 = AED50,70,000
8ECL provision (PD 68.2% × EAD AED61.8L × LGD 72%)AED30,36,000
9Higher of regulatory / ECL provisionAED50,70,000 (regulatory higher)
Required provision
AED50,70,000
Prior provision (Doubtful D1)
AED39,20,000 (D1: 25% sec + 100% unsec)
AUDIT: Reclassified from Doubtful D1 to Doubtful D2 on Nov 14, 2025 (DPD 821, crossed 821-day D2 threshold). Security revalued: prior valuation AED24L (Aug 2024), updated to AED18.5L (distressed forced-sale, Sep 2025 valuation report). Incremental provision: +AED11,50,000. CBS updated. Authorisation: Provisioning AI system rule PR-D2-PARSEC-001. Valuation source: Empanelled valuer report Sep 14, 2025.
Total provision — these 3 accounts
AED76,01,000
Incremental over prior quarter
+AED24,06,640
The audit trail: every provision change is traceable to its cause
Provision Audit Trail — LA-2024-4821 · Rajan Textiles · Full history
All classification changes and provision updates · Immutable log
May 5, 2025
00:01:14
SYSTEM
Account originated: Standard. Provision set at AED11,360 (0.40% general provision on AED28.4L outstanding). Classification: Standard. DPD: 0.
HASH: a4f2e98bc1d3 · Data source: LOS-2024-4821 at origination
Aug 14, 2025
00:02:08
SYSTEM
First overdue date recorded. DPD count commenced. Account: Standard. instalment due Aug 5, 2025 not received by Aug 14, 2025 (grace period expired). 90-day watch timer started. Collection team alerted.
HASH: c8a1f3d92b44 · Source: CBS payment register Aug 14, 2025
Sep 28, 2025
09:14:22
COLL TEAM
75-day watch alert responded to: Field visit conducted. Borrower confirms temporary cash flow difficulty from delayed receivables. PTP (Promise to Pay) for Oct 10. Account remains Standard. Provision: AED11,360.
HASH: e9d5a12f4b88 · Agent: R. Subramaniam · Call log ref: CL-2025-48821
Oct 10, 2025
00:02:11
SYSTEM
PTP not honoured. DPD: 57 days. 85-day watch alert sent to collection team. Account: Standard (DPD <90).
HASH: b3c8e74a1f02 · CBS: no credit received by PTP date
Nov 14, 2025
00:04:22
SYSTEM
DPD crossed 90-day threshold (DPD: 91). Account reclassified Standard → Sub-Standard. Provision recalculated: 15% of AED28.4L outstanding = AED4,26,000. Change: +AED4,14,640. CBS updated. Collection team notified. Regulatory reporting flag set.
HASH: f7a2d3c09e14 · Rule applied: PR-SUBST-001 · Outstanding: AED28,40,000 verified from CBS
BothCentral Bank Loan Classification Norms regulatory and IFRS 9 ECL computed for every NPL account — higher amount applied
FullAudit trail for every provision change — source data, rule applied, timestamp, hash · Immutable
AED76LCombined provision for 3 accounts — each computed from actual outstanding, security value, and DPD
ZeroManual intervention in the calculation chain — every figure traceable to CBS source data and Central Bank Loan Classification Norms rule
The calculation that cannot be audited will be challenged — and the challenge will succeed
A provisioning figure that an auditor or regulator cannot trace to its source data — which account, which outstanding balance, which security value, which Central Bank Loan Classification Norms rate, computed on which date — is a figure that can be challenged regardless of whether it is mathematically correct. The correctness of the number is not the same as the defensibility of the calculation. The Provisioning AI generates a calculation that is not only correct — it is traceable at every step to the source data that drove it, timestamped to the second, and immutably logged so that the audit question "how did you arrive at this provision amount?" has a complete, verifiable answer for every account in the portfolio.