ANZ Non-Financial Risk management: Promontory First Report

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. 

On 7 November 2025, APRA approved ANZ’s Root Cause Remediation Plan (RCRP). The RCRP is a comprehensive plan that details the activities the People, Accountability, Customers and Trust (PACT) Program expects to take to meet our aspirational and regulatory requirements to uplift NFR management, enterprise wide. 

Promontory was appointed as the Independent Reviewer under the CEU to assess the progress of the execution of the RCRP.  

Promontory’s First Report, released on 30 April 2026, covers the Enterprise NFR Program progress for the period 1 October 2025 to 31 March 2026. It is available here: Promontory First Report – 30 April 2026

Promontory’s report focuses on the adequacy of mobilisation arrangements, governance structures and their operation, and the early delivery of the Enterprise NFR Program.  

Their Establishment Report, which is available here Promontory Establishment Report - 14 November 2025, confirmed that the NFR Program design, governance arrangements, and overall setup are appropriate to deliver on the commitments outlined in the RCRP.   

Subsequent reports will cover standard quarterly periods and will be issued every six months.