As import substitution in software has gained momentum, banks are facing mounting costs on domestic software solutions. Under the Bank of Russia’s general requirements, such assets are subject to an immediate one‑time deduction from core capital, which places considerable strain on capital adequacy ratios.
The regulator has provided a mechanism to ease this burden — banks may apply a deduction of IA cost from equity capital gradually over a period of four years. However, the preferential treatment can only be utilised if four mandatory conditions are simultaneously met, one of which is obtaining independent audit assurance report under ISAE 3000.
FBK’s new service (full details available at the link) helps banks lawfully exercise this right to a phased deduction. We perform a thorough review of your assets' compliance with the provisions of Executive Order No. 16 dated 30 March 2022, and Federal Law No. 187‑FZ dated 26 July 2017, and also verify that the software is duly recorded in the official registers of the Federal Service for Technical and Export Control (FSTEC) and the Ministry of Digital Development of Russia. This helps institutions manage the impact on capital and mitigate regulatory risks.
‘FBK's expertise is in full compliance with the Bank of Russia's recommendations on auditor selection. The firm is included in the register of entities providing services to systemically important financial market institutions and has conducted over 100 audits of credit institution financial statements over the past five years,’ noted Alexey Terekhov, Managing Partner for Financial Services Industry at FBK.
