SCRA under CRR III - Theory is yesterday. Now it’s about implementation.

Both the use of external ratings and the SCRA classification must not be exclusively automated. Credit institutions must ensure that, in both cases, an internal review takes place as part of the due diligence process in accordance with Article 79 of the CRD. In addition to the ‘hard facts’, qualitative factors must also be taken into account. Moreover, the entire process must be firmly embedded in the bank’s internal procedures and documented in a traceable and auditable manner.

So much for the legal framework – yet until recently, both institutions and large rating agencies were hesitant to move into implementation. This was largely due to regulatory details not being finalised for a long time.

Rather than waiting, we began continuously analysing the available foundations as early as autumn 2023 – and started developing our end-to-end solution, FinAPU SCRA. This has put us and our clients in a unique position: while many still publish whitepapers or discuss theoretical considerations, we’ve gone all-in on practice – and can clearly demonstrate proof of concept.

FinAPU SCRA is already in productive use at more than 20 clients – fully automated, DORA-compliant, and audit-proof. The calculation and monitoring of SCRA grades in real time, as well as the due diligence examinations required by regulators, are automated – transparent, efficient, and fully auditable. The qualitative assessments made by analysts are ensured and documented through audit-compliant workflows.

SCRA is not a question of faith - but of calculation
The first reporting deadline is just around the corner in June. And with it the realisation from the first few months: Manually maintained ratings, Excel-based evaluations, or bloated standard packages from large providers simply don’t match the complexity – especially when hundreds of unrated exposures must be classified under SCRA.

What is needed now: structured data, a robust rulebook and seamless monitoring. This is where regulatory expectations meet real-world execution. What counts is depth, not declarations.

FinAPU therefore delivers:

• Automated grade calculation based on up-to-date financial data
• Real-time monitoring and early warning indicators
• DORA-compliant documentation and historization
• Integrable interfaces with credit processes and regulatory reporting
• Audit-proof workflows for quantitative and qualitativ assessments

Automation that truly relieves the burden
Manual, error-prone processes in isolated Excel sheets are a thing of the past in modern risk management. One of the core goals in developing FinAPU SCRA was to maximise automation – not just to support our clients, but to reliably and almost entirely relieve them of day-to-day operational and regulatory burdens.

Two key advantages FinAPU SCRA delivers:

• Ongoing, automated calculation of SCRA grades with just a few clicks
• Structured execution of due diligence checks in line with CRD expectations

FinAPU SCRA not only saves valuable internal resources, but also ensures greater accuracy, consistency and auditability - and noticeably reduces the burden on institutions.

No reporting without monitoring - no grade without governance
SCRA doesn't just mean assigning a rating. It’s about justifying it, documenting it, and monitoring it continuously. This is exactly where it becomes clear who only provides reports - and who really takes on regulatory responsibility.

FinAPU combines:

• a transparent technical concept
• with a compliant application in accordance with Articles 138 - 141 of the CRR
• and the possibility of bank-specific calibration, e.g. via internal collateral logic, risk transfers

From the field: Big players, big price – but little process?
In the early months of CRR III, some providers mainly promoted their brand and reach. In practice, however, we’re hearing from more and more institutions dissatisfied with these tools – because they don’t offer a real solution.

The feedback is strikingly consistent:

• No end-to-end monitoring
• No early warning systems
• Lack of DORA-compliance
• High ongoing costs, with low automation
• Only data delivery – no front end or SCRA calculation
• Insufficient data for small banks under national regulation
• Delays between financial statements and public disclosure
• No audit-proof workflows for qualitative assessment

Conclusion: Ready for CRR III? We are.
CRR III leaves no room for interpretation. Anyone who relies on gut feeling, ratings with a ‘double bottom’ or annually updated third-party lists for SCRA categorisation is taking unnecessary risks - both operationally and reputationally. 

SCRA is mandatory - and FinAPU is the reference against which other solutions can currently be measured. Learn more now at www.finapu.com/en/scra or arrange a free consultation directly.