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Our commitment to uplifting non-financial risk
ANZ is focused on implementing sustained improvements to our non-financial risk management and risk culture across the Bank.
Copies/summaries of some of ANZ's key documents related to our response to APRA’s Court Enforceable Undertaking can be found below.
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Embedding sustainable bank-wide improvements in our culture, accountability and non-financial risk
ANZ entered a Court Enforceable Undertaking (CEU) with the Australian Prudential Regulation Authority (APRA) on 3 April 2025, following APRA’s concerns about ANZ’s non-financial risk (NFR) management practices and risk culture.
The CEU takes effect as a legally binding commitment from ANZ to APRA, and commits ANZ to take specific actions to address risk weaknesses and deficiencies identified by APRA and in the root-cause analysis conducted under the CEU.
We have acknowledged APRA’s concerns. We have established Program PACT (People, Accountability, Customers and Trust) to deliver on our commitments, which align to our broader ambition to build a strong, risk-aware culture that prioritises accountability and consistently delivers good customer, risk and business outcomes, to manage NFR. ANZ’s obligations under the CEU reinforce the urgency and scope of the Program.
Delivery of the Root Cause Remediation Plan
Strengthening NFR management is a strategic imperative for ANZ to protect customers, enable resilient operations, and sustain trust.
On 7 November 2025 APRA approved our Root Cause Remediation Plan (RCRP). The RCRP is a comprehensive plan that details the activities that Program PACT 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.
In embedding the RCRP, Program PACT will continue to prioritise good customer, risk and business outcomes to ensure that:
- We reliably deliver the experience our customers should expect
- We manage risk well and deliver results in the right way
- We understand our operating environment and execute at pace
- We prioritise what matters most
- We have the right people, with the right capabilities
Our Root Causes
ANZ’s RCRP was developed following an enterprise-wide independent review to identify the root causes and behavioural drivers of shortcomings in ANZ’s NFR management practices and risk culture.
A summary of the root causes was published on 14 November 2025 and is available here.
ANZ has appointed Promontory to provide independent assurance of ANZ’s progress against the RCRP. Updates will be made available here.