ANZ has taken steps to address concerns raised by the Australian Prudential Regulation Authority (APRA) regarding its non-financial risk management practices and risk culture. On April 3, 2025, ANZ entered into a Court Enforceable Undertaking with APRA after the regulator expressed concerns about how the bank managed non-financial risks.
Following an independent review across the organization to identify root causes and behavioral drivers behind deficiencies in its risk management, ANZ developed a comprehensive Root Cause Remediation Plan (RCRP). This plan outlines the actions that will be taken as part of the PACT Program to meet both regulatory and internal requirements for improving non-financial risk management throughout the enterprise. Senior members of ANZ’s management have been assigned responsibility for overseeing and delivering on this plan.
APRA approved ANZ’s RCRP on November 7, 2025. According to ANZ, “The RCRP is a comprehensive plan that details the activities the PACT Program expects to take to meet our aspirational and regulatory requirements to uplift NFR management, enterprise wide. Accountability for the delivery and oversight of the RCRP has been assigned to members of ANZ’s senior management.”
On November 14, 2025, ANZ published a summary of its root cause analysis which identified key issues within its non-financial risk framework. The summary can be accessed at Root Cause Analysis Summary - 14 November 2025.
To ensure transparency and accountability in implementing these changes, ANZ appointed Promontory as an independent party to provide assurance on progress made against the remediation plan. Promontory’s Establishment Report is available at Promontory Establishment Report - 14 November 2025.
ANZ plans to publish further updates on its website at Our commitment to uplifting non-financial risk | ANZ as it continues work on enhancing its approach to managing non-financial risks.