A key risk indicator (KRI) is a metric that moves before a risk crystallises, read against thresholds that say when someone has to act. A usable one has five parts: the metric, its green, amber and red thresholds, the system it comes from, the person who answers for it, and how often it refreshes. An indicator missing any of the five is a dashboard decoration. This page is a reference library of KRI examples built on that pattern: thirteen tables covering credit, liquidity, interest rate, market, operational, technology and cyber, fraud and financial crime, compliance and conduct, people and culture, third-party, reputation and ESG, and model risk, each with illustrative thresholds to calibrate, followed by a breadth list across sixteen risk categories, a guide to setting thresholds, the tests internal audit applies to a KRI program, and a worked audit at an illustrative nine-billion-dollar bank.
It absorbs the former guide to non-financial risk indicators (people, culture, conduct, third parties, reputation and ESG now have tables of their own) and pairs with the KRI program design guide, which covers selection, governance and escalation. The thresholds are starting points drawn from banking and corporate practice, not standards; the calibration section explains how to set your own.
In this guide
- What makes a KRI usable: the five fields and the KPI distinction
- Credit risk KRIs
- Liquidity risk KRIs
- Interest rate risk KRIs
- Market risk KRIs
- Operational risk KRIs
- Technology and cyber risk KRIs
- Fraud and financial crime KRIs
- Compliance and conduct risk KRIs
- People and culture KRIs
- Third-party and supply chain KRIs
- Reputation, ESG and climate KRIs
- Model and data risk KRIs
- The breadth list: indicators by risk category
- Setting thresholds: five calibration methods
- How internal audit tests a KRI program
- Worked example: Lakeshore Bancorp’s KRI library audit
- Frequently asked questions
- Related guides
What makes a KRI usable: the five fields and the KPI distinction
The discipline behind every table below comes from COSO’s enterprise risk management framework and the guidance on developing key risk indicators that COSO published with the North Carolina State University ERM Initiative: a good indicator is leading rather than lagging where a leading measure exists, traces to a root cause of the risk rather than to its consequence, and connects to a stated risk appetite, which is what the threshold columns force the owner to write down. Three related terms are run together in most risk reports, and the first thing an auditor does with a KRI inventory is sort them.
| Term | What it measures | Example | Who uses it |
|---|---|---|---|
| Key performance indicator (KPI) | Achievement of an objective, after the fact | Loan growth 8 per cent against a 10 per cent plan | Management, for performance |
| Key risk indicator (KRI) | The build-up of exposure to a risk, ahead of the loss | Policy exceptions on new originations at 9 per cent of approvals | Risk committees, for early warning |
| Key control indicator (KCI) | Whether a control is operating | Reconciliations completed within three days: 94 per cent | Control owners and the second line |
| Loss or event metric | What already happened | Operational losses year to date | Capital and lessons learned; lagging by definition |
A KRI library has a recognisable shape when it works. Each indicator carries the five fields; thresholds are tied to appetite statements and regulatory floors; the source system is named so the number can be reproduced; the owner is a person, not a department; and the refresh cadence matches how fast the risk moves (daily for liquidity, quarterly for culture). The risk register guide shows where the indicators attach to risks, and the auditing ERM guide covers the program they sit inside.
Credit risk KRIs
Credit indicators are the most mature family because the data is transactional and the regulatory floors are explicit. The pattern to watch is migration: early delinquency and watchlist downgrades move a year or more before charge-offs, and policy exceptions on new business move before either. The credit risk guide covers the measurement behind each row.
| Indicator | Green | Amber | Red | Source system | Owner · refresh |
|---|---|---|---|---|---|
| Non-performing loans to total loans | Below 1.5% | 1.5–3% | Above 3% | Loan servicing system | Chief credit officer · monthly |
| 30–89 day past-due ratio (early delinquency) | Below 1% | 1–2% | Above 2% | Loan servicing system | Portfolio manager · monthly |
| Net watchlist migration (downgrades less upgrades) in the quarter | Below 2% of the rated book | 2–5% | Above 5% | Credit MIS | Head of credit risk · quarterly |
| Policy exceptions on new originations | Below 5% of approvals | 5–10% | Above 10% | Loan origination system | Credit administration · monthly |
| Top-20 borrower exposure to Tier 1 capital | Below 80% | 80–120% | Above 120% | Credit data warehouse | Chief risk officer · quarterly |
| Commercial real estate loans to total capital (supervisory screen 300%) | Below 250% | 250–300% | Above 300% | Credit data warehouse | Chief credit officer · quarterly |
| Allowance coverage of non-performing loans | Above 120% | 80–120% | Below 80% | Allowance model | Controller · quarterly |
| Annual reviews overdue on exposures above the review threshold | 0 | 1–5% of required reviews | Above 5% | Credit workflow system | Credit administration · monthly |
Liquidity risk KRIs
Liquidity indicators have to refresh faster than any other family: the 2023 bank failures showed deposits leaving at a pace measured in hours, which is why the deposit-mix rows below are daily or weekly and why survival horizon sits beside the regulatory ratios. The liquidity risk guide explains each metric, the stress testing guide the horizon measures, and the liquidity audit program the tests.
| Indicator | Green | Amber | Red | Source system | Owner · refresh |
|---|---|---|---|---|---|
| Liquidity coverage ratio (regulatory floor 100% where it applies) | Above 115% | 100–115% | Below 100% | Treasury or ALM system | Treasurer · daily |
| Net stable funding ratio | Above 110% | 100–110% | Below 100% | ALM system | Treasurer · monthly |
| Survival horizon under the combined stress scenario | Above 90 days | 30–90 days | Below 30 days | Liquidity stress model | ALCO · weekly |
| Uninsured deposits to total deposits | Below 30% | 30–50% | Above 50% | Core banking | Treasurer · weekly |
| Top-10 depositor concentration | Below 10% of deposits | 10–20% | Above 20% | Core banking | Treasury · monthly |
| Wholesale and brokered funding to total funding | Below 15% | 15–25% | Above 25% | ALM system | Treasurer · monthly |
| Unencumbered high-quality liquid assets to 30-day stress outflows | Above 125% | 100–125% | Below 100% | Treasury system | ALCO · weekly |
| Contingency funding capacity drawn (discount window, FHLB, repo) | 0% | Below 10% | 10% or more | Treasury system | ALCO · monthly |
| Collateral pledged and tested at the discount window and FHLB in the last quarter | Tested, capacity confirmed | Pledged, untested | Not pledged | Collateral management | Treasurer · quarterly |
Interest rate risk KRIs
Interest rate risk indicators should cover both lenses (economic value and earnings), the assumptions that drive them, and the governance around limit breaches. The weakest programs report NII sensitivity only, which is the pattern the Federal Reserve’s review of Silicon Valley Bank described. The interest rate risk guide covers the measures, the Basel 2024 recalibration and the supervisory outlier tests behind the first two rows.
| Indicator | Green | Amber | Red | Source system | Owner · refresh |
|---|---|---|---|---|---|
| EVE sensitivity in the worst of the six standard shocks, as a share of Tier 1 (EU outlier threshold 15%) | Below 10% | 10–15% | Above 15% | ALM model | ALCO · monthly |
| NII sensitivity, 12 months, parallel 200bp shock, as a share of projected NII | Below 8% | 8–12% | Above 12% | ALM model | ALCO · monthly |
| Limit utilisation across all board IRR limits | Below 75% | 75–100% | Any breach | ALM model and limit log | Treasurer · monthly |
| Breaches outstanding past the policy cure period | 0 | 1 | 2 or more | Limit log | ALCO · monthly |
| Realised deposit beta versus modelled beta, trailing 12 months | Within 5 points | 5–10 points | Above 10 points | Deposit study and ALM model | ALM manager · quarterly |
| Key assumption changes since the last board approval (betas, decay, prepayment) | None without approval | Approved, backtested within 90 days | Unapproved or unbacktested | Model change log | ALM manager · quarterly |
| Unrealised losses on securities to tangible common equity | Below 15% | 15–30% | Above 30% | Investment accounting | CFO · monthly |
| Model validation findings open on the ALM model | 0 high | 1 high with a dated plan | Any high past its date | Model inventory | Model risk management · quarterly |
Market risk KRIs
Market risk indicators exist for institutions with trading books, investment portfolios or hedging programs. The rows combine limit utilisation, model performance (backtesting) and the valuation controls that caught or missed the losses in the market risk guide‘s history table.
| Indicator | Green | Amber | Red | Source system | Owner · refresh |
|---|---|---|---|---|---|
| Value-at-risk utilisation against the board limit | Below 70% | 70–100% | Any breach | Risk engine | Head of market risk · daily |
| VaR backtesting exceptions in the trailing 250 days (Basel green zone up to 4) | 0–4 | 5–9 | 10 or more | Risk engine | Head of market risk · monthly |
| Stress loss under the worst approved scenario to Tier 1 | Below 5% | 5–10% | Above 10% | Stress testing system | Risk committee · monthly |
| Desk limit breaches and time to resolution | 0 open | Open, within 1 day | Open beyond 1 day | Limit monitoring | Head of market risk · daily |
| Independent price verification variances above tolerance, unresolved | 0 | 1–5 positions | Above 5 or any Level 3 unresolved | IPV system | Product control · monthly |
| Stale prices in the end-of-day valuation (no price update within policy) | Below 0.5% of positions | 0.5–2% | Above 2% | Valuation system | Product control · daily |
| Unexplained P&L (actual less risk-based) above threshold | 0 days in the month | 1–2 days | 3 or more | P&L attribution | Product control · daily |
| Hedge effectiveness tests failed (hedge accounting programs) | 0 | 1 | 2 or more | Hedge accounting system | Treasurer · quarterly |
Operational risk KRIs
Operational risk indicators are the broadest family and the easiest to overbuild. The rows below are the ones that predict losses in most institutions: ageing reconciliation items, processing errors, change failures, resilience test results and the backlog of audit and regulatory issues. The RCSA guide shows how the indicators tie to the self-assessment.
| Indicator | Green | Amber | Red | Source system | Owner · refresh |
|---|---|---|---|---|---|
| Operational losses year to date against the annual loss budget, pace | Below 50% | 50–100% | Above 100% | Loss event system | Head of operational risk · monthly |
| Unreconciled items aged over 30 days, by value | None material | Non-material aged items | Material items aged | Reconciliation tool | Controller · monthly |
| Processing error rate in high-volume operations (payments, servicing) | Below 0.1% | 0.1–0.3% | Above 0.3% | Quality control sampling | Operations head · monthly |
| Failed or rolled-back changes to production | Below 3% of changes | 3–7% | Above 7% | Change management system | CIO · monthly |
| Critical system availability | 99.9% or above | 99.5–99.9% | Below 99.5% | ITSM and monitoring | CIO · monthly |
| Business services with recovery tests overdue | 0 | 1–2 | 3 or more, or any critical service | Resilience program | COO · quarterly |
| Overdue high-risk audit issues | 0 | 1–2 | 3 or more | Issue tracking system | Chief audit executive · monthly |
| Regulatory findings (MRAs and equivalents) past their committed date | 0 | 1 | 2 or more | Regulatory issue log | Chief risk officer · monthly |
| Near-miss events reported against losses (a reporting-culture measure) | Above 3 to 1 | 1 to 3 to 1 | Below 1 to 1 | Loss event system | Head of operational risk · quarterly |
Technology and cyber risk KRIs
Cyber indicators are leading where they measure exposure (unpatched critical vulnerabilities, privileged access without multi-factor authentication) and lagging where they count incidents. Both are needed; the mistake is to report only the incident count, which is low until the week it is not.
| Indicator | Green | Amber | Red | Source system | Owner · refresh |
|---|---|---|---|---|---|
| Critical vulnerabilities open past the remediation SLA (15 days is common) | 0 | 1–10 | Above 10, or any internet-facing | Vulnerability scanner | CISO · weekly |
| Privileged accounts without multi-factor authentication | 0 | Any with a dated remediation plan | Any without a plan | Identity and access management | CISO · monthly |
| Phishing simulation failure rate | Below 5% | 5–10% | Above 10% | Security awareness platform | CISO · quarterly |
| Mean time to detect security incidents | Below 24 hours | 24–72 hours | Above 72 hours | SIEM | SOC manager · quarterly |
| End-of-life systems in production | 0 | Isolated, with compensating controls | Any internet-facing | Configuration management database | CIO · quarterly |
| User access reviews overdue for critical applications | 0 | 1–2 applications | 3 or more | IAM or GRC system | Application owners · quarterly |
| Backup restoration tests failed or overdue for critical systems | 0 | 1 | 2 or more | Backup system | CIO · quarterly |
| Third parties with access to production data lacking a current security assessment | 0 | 1–3 | Above 3 | Vendor risk system | CISO · quarterly |
Fraud and financial crime KRIs
Fraud and anti-money-laundering indicators measure three things: losses against appetite, the backlog in detection (alerts unworked, due diligence overdue) and the integrity of the reporting channel. The fraud risk management guide and the BSA/AML testing guide cover the programs behind the rows.
| Indicator | Green | Amber | Red | Source system | Owner · refresh |
|---|---|---|---|---|---|
| Confirmed fraud losses year to date against the loss appetite, pace | Below 50% | 50–100% | Above 100% | Fraud case system | Head of fraud · monthly |
| Fraud alerts unworked beyond 5 days | Below 2% of alerts | 2–5% | Above 5% | Transaction monitoring | Fraud operations · weekly |
| Card and payment chargeback rate | Below 0.5% | 0.5–0.9% | Above 0.9% | Payments platform | Payments risk · monthly |
| AML alert backlog beyond the investigation SLA | 0 | Below 5% of open alerts | 5% or more | AML monitoring system | BSA officer · weekly |
| Suspicious activity reports filed late | 0 | 1–2 in the quarter | 3 or more | Case management system | BSA officer · quarterly |
| High-risk customers with overdue enhanced due diligence | 0 | Below 2% | 2% or more | Customer due diligence system | BSA officer · monthly |
| Sanctions screening list updates applied late | 0 | 1 | 2 or more | Screening system | Sanctions officer · monthly |
| Whistleblower investigations open beyond 60 days | 0 | 1–2 | 3 or more | Case management system | General counsel or ethics officer · quarterly |
Compliance and conduct risk KRIs
Compliance indicators should show the level of the risk, not the activity of the function: training completion is an input, the share of issues found by examiners rather than by the program is an outcome. Conduct indicators look for the incentives and behaviours that precede customer harm. The compliance risk guide and the conduct risk guide develop both.
| Indicator | Green | Amber | Red | Source system | Owner · refresh |
|---|---|---|---|---|---|
| High residual risk cells in the compliance risk assessment with overdue action plans | 0 | 1–2 | 3 or more | Compliance risk assessment | Chief compliance officer · quarterly |
| Share of compliance issues identified by examiners or auditors rather than by the program | Below 15% | 15–30% | Above 30% | Issue log | Chief compliance officer · quarterly |
| Regulatory changes past their effective date without validated implementation | 0 | 1 | 2 or more | Regulatory change log | Compliance · monthly |
| Complaints per 1,000 accounts, by product, with allegation categories | Within product baseline | Up 25% on baseline | Up 50% or any discrimination allegation untriaged | Complaint system | Compliance · monthly |
| Repeat compliance issues (same root cause as a closed issue) | 0 | 1 | 2 or more | Issue log | Chief compliance officer · quarterly |
| Sales incentive clawbacks and cancelled-within-30-days products as a share of sales | Below 2% | 2–5% | Above 5% | Sales and incentive systems | Head of conduct risk · monthly |
| Employees in high-risk roles below the comprehension threshold on role-based training | Below 5% | 5–10% | Above 10% | Learning system | Compliance · quarterly |
| Open regulatory matters with a missed milestone | 0 | 1 | 2 or more | Regulatory issue log | Chief risk officer · monthly |
People and culture KRIs
People indicators are the non-financial family most often missing from risk reports, and the one that explains many operational and conduct losses after the fact: turnover in a control function, a hotline that goes quiet, investigations that do not close. The organizational behavior topical requirement sets what the Standards now expect internal audit to assess in this area.
| Indicator | Green | Amber | Red | Source system | Owner · refresh |
|---|---|---|---|---|---|
| Turnover in critical control roles (finance, risk, compliance, information security), rolling 12 months | Below 10% | 10–20% | Above 20% | HR information system | Chief people officer · quarterly |
| Vacancies in control functions open beyond 90 days | 0 | 1–2 | 3 or more | HR information system | Chief people officer · monthly |
| Engagement survey score in control functions versus the enterprise | At or above enterprise | Up to 5 points below | More than 5 points below | Survey platform | Chief people officer · annual or pulse |
| Ethics hotline reports per 100 employees (very low and very high both warrant attention) | Within 0.5–2 | Below 0.5 or 2–3 | Below 0.2 or above 3 | Hotline system | Ethics officer · quarterly |
| Substantiation rate of hotline reports | 15–40% | Below 15% or above 40% | Below 5% or above 60% | Case management system | Ethics officer · quarterly |
| Investigations open beyond 60 days | 0 | 1–2 | 3 or more | Case management system | General counsel · monthly |
| Retaliation complaints following a report | 0 | 1 | 2 or more | Case management system | General counsel · quarterly |
| Exit interviews citing pressure to bypass controls or ethical concerns | 0 | 1–2 in the quarter | 3 or more, or any in a control function | HR information system | Chief people officer · quarterly |
| Mandatory training overdue in high-risk roles | 0 | Below 5% | 5% or more | Learning system | Compliance · monthly |
Third-party and supply chain KRIs
Third-party indicators track the risk that an outsourced or supplied service fails, and the gap between the inventory and the oversight. The third-party risk management guide and the Third-Party Topical Requirement cover the program; the rows below are the ones that move first.
| Indicator | Green | Amber | Red | Source system | Owner · refresh |
|---|---|---|---|---|---|
| Critical third parties without a current risk assessment | 0 | 1–2 | 3 or more | Vendor risk system | Head of third-party risk · quarterly |
| Critical third parties with SLA breaches in the quarter | Below 5% | 5–15% | Above 15% | Contract management | Business owners · quarterly |
| Critical services dependent on a single supplier with no tested exit plan | 0 | 1–2 | 3 or more | Vendor inventory | COO · annual |
| Fourth parties identified for critical services | 100% identified | 80–99% | Below 80% | Vendor risk system | Head of third-party risk · annual |
| Third-party incidents affecting the organisation (outages, breaches) in the quarter | 0 | 1 | 2 or more | Incident system | COO · quarterly |
| Suppliers with deteriorating financial health scores | Below 5% of critical | 5–10% | Above 10% | Financial monitoring service | Procurement · quarterly |
| On-time delivery and defect rate for critical suppliers (manufacturing and retail) | Within contract | Below contract in one period | Below contract in two periods | ERP | Supply chain head · monthly |
| Contracts for critical services expiring within 6 months without a renewal decision | 0 | 1–2 | 3 or more | Contract management | Procurement · monthly |
Reputation, ESG and climate KRIs
Reputation indicators are the hardest to make leading, because reputation is lost when a failure elsewhere becomes public; the usable ones measure the inputs (complaints, sentiment, incidents) rather than the outcome. ESG and climate indicators have become compliance obligations in several jurisdictions, with assured disclosures under the EU’s sustainability reporting directive, ISSB-based standards and California’s climate disclosure laws, which is why disclosure data quality has its own row. The ESG auditing guide covers the assurance program and the reputation risk introduction the category itself.
| Indicator | Green | Amber | Red | Source system | Owner · refresh |
|---|---|---|---|---|---|
| Negative media and social mentions, weekly volume versus baseline | Within baseline | Up 50% | Up 100% or any viral incident | Media monitoring | Head of communications · weekly |
| Customer complaints escalated to a regulator or ombudsman | Within baseline | Up 25% | Up 50% | Complaint system | Compliance · monthly |
| Net promoter or customer satisfaction score, trend | Stable or rising | Down one period | Down two periods | Survey platform | Chief customer officer · quarterly |
| Environmental incidents and regulatory notices | 0 | 1 minor | Any reportable | EHS system | Head of EHS · monthly |
| Scope 1 and 2 emissions against the published reduction pathway | On pathway | Up to 10% behind | More than 10% behind | Sustainability data platform | Chief sustainability officer · quarterly |
| Sustainability disclosure data points without a documented source and control | 0 | Below 5% | 5% or more | Disclosure controls inventory | Controller · quarterly |
| Sites or assets in high physical climate risk zones without an adaptation plan | 0 | Below 10% of critical sites | 10% or more | Physical risk assessment | COO · annual |
| Supplier ESG assessments overdue for high-risk categories | 0 | Below 10% | 10% or more | Vendor risk system | Procurement · quarterly |
Model and data risk KRIs
Model indicators measure the inventory, the validation backlog and performance in use; data indicators measure the quality of the inputs every other table depends on. With AI systems now in credit, marketing and servicing, the inventory row should include them. The model risk audit guide and the AI governance audit guide cover the frameworks.
| Indicator | Green | Amber | Red | Source system | Owner · refresh |
|---|---|---|---|---|---|
| Tier 1 models (and AI systems) with validation overdue | 0 | 1 | 2 or more | Model inventory | Head of model risk · quarterly |
| High-severity validation findings open past their due date | 0 | 1–2 | 3 or more | Model inventory | Head of model risk · quarterly |
| Models in production with ongoing-monitoring breaches unresolved | 0 | 1 | 2 or more | Monitoring reports | Model owners · monthly |
| Models in use not on the inventory (found by audit or by the second line) | 0 | 1 | 2 or more | Audit and validation findings | Head of model risk · annual |
| Critical data elements failing quality rules | Below 1% | 1–3% | Above 3% | Data quality platform | Chief data officer · monthly |
| Regulatory reports resubmitted or corrected in the year | 0 | 1 | 2 or more | Regulatory reporting log | Controller · quarterly |
| Manual adjustments to model outputs or reports as a share of items | Below 2% | 2–5% | Above 5% | Reporting system | Report owners · quarterly |
| AI systems in customer-facing decisions without a bias and performance review in 12 months | 0 | 1 | 2 or more | AI inventory | Head of model risk · quarterly |
The breadth list: indicators by risk category
For completeness beyond the thirteen tables, the list below spans sixteen risk categories with the indicators most commonly monitored in each. It is a checklist for building a risk universe or challenging whether a category has been left unmeasured, not a set of thresholds; the risk taxonomy guide shows how the categories fit together and the OCC risk categories guide how a bank supervisor groups them.
| Risk category | Commonly monitored indicators |
|---|---|
| Financial and capital | Capital ratios against buffers and triggers, leverage, earnings at risk, value at risk, interest rate sensitivity, currency and commodity exposures, counterparty exposure, rating agency outlook |
| Credit | Delinquency and non-performing ratios, migration, policy exceptions, concentrations, allowance coverage, overdue reviews, covenant breaches |
| Liquidity | Coverage and funding ratios, survival horizon, deposit concentration and insured share, wholesale reliance, contingency capacity, collateral readiness |
| Market | Limit utilisation, backtesting exceptions, stress losses, valuation variances, stale prices, unexplained profit and loss |
| Operational | Losses and near misses, reconciliation ageing, error rates, change failures, availability, resilience test results, overdue issues |
| Technology and cyber | Vulnerabilities past SLA, privileged access without MFA, phishing failure, detection time, end-of-life systems, access reviews, backup tests |
| Fraud and financial crime | Losses against appetite, alert backlogs, chargebacks, late suspicious activity reports, overdue due diligence, screening currency |
| Compliance and conduct | High residual risk cells overdue, examiner-found share, changes past effective date, complaints per thousand, repeat issues, incentive clawbacks |
| Legal | Open litigation by exposure, contracts without legal review, unenforceable guarantees found, intellectual property disputes, regulatory enquiries |
| People and culture | Turnover in control roles, long-open vacancies, engagement gaps, hotline volume and substantiation, investigation ageing, retaliation complaints |
| Third-party and supply chain | Critical vendors unassessed, SLA breaches, single-source dependencies, fourth parties unknown, supplier financial health, delivery and defect rates |
| Reputation | Negative mentions, regulator-escalated complaints, satisfaction trends, executive and product controversies in the press |
| Environmental, social and climate | Incidents and notices, emissions against pathway, disclosure data controls, physical risk exposure, supplier ESG assessments, health and safety rates |
| Strategic | Market share trend, revenue concentration, strategic initiative milestones missed, acquisition integration measures, competitor and technology disruption signals |
| Model and data | Validations overdue, open high findings, monitoring breaches, uninventoried models, data quality failures, report resubmissions, manual adjustments |
| Business continuity and resilience | Recovery tests overdue, recovery time objectives missed in tests, critical services without impact tolerances, crisis exercises completed, insurance adequacy |
Setting thresholds: five calibration methods
Every number in the tables above is a starting point. The durable part of the pattern is that each indicator has thresholds with a written rationale; the numbers themselves come from one of five sources, and a good KRI library records which.
| Method | How it works | Best for | Weakness |
|---|---|---|---|
| Regulatory floor plus a buffer | Red at the regulatory minimum, amber at a management buffer above it, green beyond | Capital, liquidity ratios, supervisory screens (the 300 per cent CRE concentration screen, the EU 15 per cent EVE outlier test) | Only exists where a regulator has set a number |
| Risk appetite statement | The board’s appetite becomes red; amber is an early warning set at a fraction of the distance | Losses against budget, concentrations, earnings sensitivity | Appetite statements are often qualitative and have to be translated |
| Historical distribution | Amber at the 75th and red at the 90th percentile of the indicator’s own history, or at a defined number of standard deviations | Operational, complaint, error and volume metrics with several years of data | History may include a period that was itself too risky; recalibrate after structural change |
| Peer benchmark | Thresholds set where the organisation would move from the middle to the worst quartile of peers | Turnover, delinquency, availability, phishing failure | Peer data is lagged and definitions differ |
| Zero tolerance | Any occurrence is red | Breaches past cure period, late regulatory filings, privileged accounts without MFA, unapproved assumption changes | Overused, it makes every month red and the indicator is ignored |
Two cautions before lifting any table into a risk report. Calibrate to the organisation’s size, complexity and stated appetite, and write the rationale down beside the threshold; a threshold with no rationale cannot be defended to an examiner or an audit committee. And test the thresholds against history: if an indicator would have been green through the organisation’s last loss event, it is measuring the wrong thing.
How internal audit tests a KRI program
For internal auditors the tables cut both ways: they are a scoping aid for the annual risk assessment and they are test criteria for management’s own indicators. An audit of a KRI program is short and specific, and its findings tend to be the same ones.
| Test | What the auditor does | Evidence | Typical finding |
|---|---|---|---|
| Five-field completeness | Takes the KRI inventory and checks every indicator for metric definition, thresholds, source, owner and refresh | KRI inventory | Thresholds missing on a third of indicators; owners named as departments |
| Coverage against the risk register | Maps indicators to the top risks in the risk register; looks for high-rated risks with no indicator and indicators with no risk | Register, inventory | Several top-ten risks have no leading indicator; culture and third-party risk unmeasured |
| Leading versus lagging mix | Classifies each indicator; a program that is all loss counts is not an early warning system | Inventory | Operational and conduct families entirely lagging |
| Threshold rationale | Asks for the basis of each threshold and whether the indicator would have been red before the last loss event | Calibration records, history | Thresholds set by consensus with no rationale; never recalibrated |
| Data lineage and reperformance | Rebuilds a sample of indicators from the named source system and compares to the reported figure | Source extracts, report | Reported figures manually adjusted; one indicator calculated differently from its definition |
| Breach response | Traces every amber and red reading in the year to the escalation, the decision and the action taken | Committee minutes, action logs | Reds reported for six months with no recorded decision |
| Reporting integrity | Checks that the board pack shows the same figures as the source, including history and threshold changes | Board packs, source reports | Thresholds relaxed mid-year without approval; history re-based |
| Program governance | Reviews ownership, annual refresh, retirement of stale indicators and addition of new ones after events | Program charter, change log | No indicator added or retired in three years |
Findings are written against outcomes: “four of the ten highest-rated risks have no leading indicator” and “red readings on the critical-vulnerability indicator were reported for seven consecutive months without a recorded decision” are findings; “the KRI program could be enhanced” is not. The issue validation guide covers closure.
Worked example: Lakeshore Bancorp’s KRI library audit
Lakeshore Bancorp is the illustrative nine-billion-dollar public regional bank used across this site, with a twenty-two person internal audit function. Its FY27 plan included a 220-hour audit of the enterprise KRI library, which had 164 indicators reported quarterly to the board risk committee. The engagement applied the eight tests above.
| Test | What the audit found | Rating |
|---|---|---|
| Five-field completeness | 164 indicators; 51 had no thresholds (reported as trend lines), 38 named a department as owner, 22 had no documented source | High |
| Coverage | Of the twelve top risks in the register, four had no leading indicator: deposit flight, conduct in the mortgage sales force, third-party concentration in the core processor, and ALM model assumption risk | High |
| Leading versus lagging | 71 per cent of indicators were lagging (loss and incident counts); the operational family was entirely lagging | Medium |
| Threshold rationale | No rationale recorded for 93 of 113 thresholds; the uninsured-deposit indicator (set at red above 60 per cent) would have been green throughout the first quarter of 2023 at a 58 per cent share | High |
| Reperformance | Twenty indicators rebuilt from source: seventeen agreed; the critical-vulnerability count excluded internet-facing systems managed by a vendor, and two liquidity ratios were taken from a spreadsheet rather than the ALM system | Medium |
| Breach response | Nine reds in the year; five had a recorded decision; the privileged-access indicator was red for seven consecutive months with no action logged | High |
| Reporting integrity | Thresholds on three indicators relaxed in Q2 by the risk function without committee approval | Medium |
| Governance | No indicator added or retired since FY24; no post-event review after a FY26 wire fraud loss | Medium |
The engagement was rated Needs Improvement. Management’s actions: a rebuilt library of 90 indicators, each with the five fields and a recorded calibration method, adopted by the board risk committee in two quarters; new leading indicators for the four uncovered risks, including uninsured-deposit share at a 30/50 per cent threshold, mortgage sales clawback rate, core processor SLA and exit-plan status, and ALM assumption changes against approval; a rule that any red reading carries a recorded decision within the reporting cycle; threshold changes reserved to the committee; and an annual refresh with a post-event review step. Internal audit validated the actions under the issue validation standard by reperforming the rebuilt library two quarters later and tracing the next four reds to decisions.
Frequently asked questions
What is a key risk indicator, with an example?
A key risk indicator is a metric that signals rising exposure to a risk before the loss arrives, read against thresholds that trigger action. Example: policy exceptions on new loan originations as a share of approvals, green below 5 per cent, amber 5 to 10, red above 10, sourced from the loan origination system, owned by the head of credit administration and refreshed monthly. The five fields (metric, thresholds, source, owner, refresh) are what make it usable.
What is the difference between a KRI and a KPI?
A KPI measures achievement of an objective after the fact (loan growth against plan); a KRI measures the build-up of exposure to a risk ahead of the loss (exceptions, concentrations, backlogs). The same number can serve as both in different reports, but a risk report built from KPIs tells the committee what happened, not what is coming. Key control indicators are a third type: they measure whether a control is operating.
How many KRIs should an organisation have?
Fewer than most have. A board-level set of twenty to forty, covering every top risk with at least one leading indicator, is typical for a mid-sized institution; business units and risk functions hold deeper sets below it. A library with 150 indicators and no thresholds is a reporting burden, not an early warning system, and the first thing an audit of the program usually recommends is retirement of indicators nobody acts on.
How should KRI thresholds be set?
From one of five sources, recorded beside the threshold: a regulatory floor plus a buffer, the board’s risk appetite statement, the indicator’s own historical distribution, a peer benchmark, or zero tolerance for events that should never occur. Test the result against history: an indicator that would have stayed green through the organisation’s last loss event is mis-calibrated. Changes to thresholds should need the same approval as the original.
What are examples of non-financial KRIs?
Turnover in critical control roles, vacancies open beyond 90 days, ethics hotline volume and substantiation rate, investigations open beyond 60 days, retaliation complaints, critical third parties without a current assessment, negative media volume against baseline, environmental incidents, emissions against the published pathway, and the share of sustainability disclosure data points without a documented control. The people, third-party and reputation tables above give thresholds for each.
Which KRIs matter most for a bank in 2026?
The ones the 2023 failures exposed: uninsured-deposit share, survival horizon under a combined stress, collateral tested at the discount window and FHLB, unrealised securities losses against tangible equity, EVE sensitivity as well as NII sensitivity, realised deposit beta against the modelled beta, and unapproved ALM assumption changes. Alongside them, the perennial credit and operational rows, and for institutions with fintech partners, the third-party rows.
How does internal audit use KRIs?
Twice over. As an input to its own risk assessment and audit plan: an amber or red indicator is a reason to move an audit forward. And as an object of audit: the program itself is tested for five-field completeness, coverage of the top risks, the leading-versus-lagging mix, threshold rationale, data lineage, breach response, reporting integrity and governance. The KRI program design guide covers the first use and the audit section above the second.
What should the board see?
A one-page set of the twenty to forty enterprise indicators with current reading, trend, threshold status and, for every amber and red, the decision taken and by whom. Not the full library, and not activity metrics presented as risk metrics. The board’s questions are whether the top risks are each measured by something leading, whether any red has gone unanswered, and whether thresholds have moved without its approval.
Related guides
- Designing a KRI Program — selection, thresholds, escalation and governance for the indicators in this library
- How to Audit the ERM Program — the program the KRI library sits inside, with maturity criteria
- The Risk Register — where each indicator attaches to a risk, with a worked example
- The Annual Internal Audit Risk Assessment — using indicators to drive the audit plan
- Liquidity Risk — the metrics behind the liquidity table, from loan-to-deposit ratio to survival horizon
- Interest Rate Risk — EVE, NII, the Basel 2024 recalibration and the outlier tests
- Credit Risk — migration, concentrations and allowance coverage
- Compliance Risk — the compliance management system the compliance indicators measure
- Conduct Risk — the behaviours the conduct indicators look for
- Third-Party Risk Management — the lifecycle program behind the third-party table
- Model Risk Audit — validation, inventory and ongoing monitoring
- Risk Management and ERM category — every guide on risk programs in one archive

Leave a Reply