Bank GRC - Excel is not good enough to communicate your strategy planning and control, your auditor will agree.
Stop relying on static spreadsheets for business planning and execution tracking. Secure, scalable solutions now exist — trusted by financial institutions.
Using excel to communicate your banks strategic/business plan throughout the organisation can lead to fines, remediation orders, public censure, or even leadership changes.
In the past there were no great, easy to use, ISO complaint tools, for this. Today there are.
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Do banks need to have a business plan with cascading into the organisation as part of their compliance or regulator?
Yes, banks are generally required or strongly expected to have a business plan that cascades into the organisation as part of regulatory compliance. This expectation is not always stated in the exact words “business plan with cascading,” but it is embedded in various regulatory requirements related to governance, risk management, strategy, and internal controls.
Key Regulatory Expectations:
| Regulation/Framework | Requirement | Applies To |
|---|---|---|
| Basel III / Basel IV | Requires robust governance, risk appetite frameworks, and strategic alignment of risk and capital. | All internationally active banks |
| ECB / EBA Guidelines | Require a documented business model and strategy with clear execution plans and KPIs. | EU-regulated banks |
| DNB (Netherlands) | Expects a clear business model, strategy, and cascading governance to business units. | Dutch banks |
| BCBS 239 | Requires risk data aggregation and reporting to be aligned with business strategy. | Systemically important banks |
| IFRS 9 / Expected Credit Loss (ECL) | Requires alignment of forecasts and strategy with credit risk provisioning. | Banks under IFRS standards |
| Internal Capital Adequacy Assessment Process (ICAAP) | Must align capital planning to strategic and business plans. | All significant EU banks |
| Internal Liquidity Adequacy Assessment Process (ILAAP) | Requires cascading liquidity strategy and stress testing. | All significant EU banks |
Practical Implication:
While the term “OGSM” or “cascading OGSM” is not used explicitly, regulators do expect banks to:
- Have a clear strategic plan (including revenue goals, capital allocation, risk appetite).
- Cascading plans and responsibilities down to departments and functions.
- Ensure alignment between high-level objectives and operational execution.
- Monitor and report KPIs and KRIs that link back to strategic goals.
- Demonstrate board-level oversight and risk-adjusted execution of plans.
Why This Matters:
- Non-compliance or failure to cascade strategy can result in supervisory actions.
- Regulators expect consistency between what is on paper and how the bank behaves operationally.
- Increasingly, strategic planning is linked to climate risk, digital transformation, and customer outcomes — areas regulators now actively review.
Regulatory and organizational performance
If a bank’s C-level team fails to cascade their strategic/business plan effectively—or uses inadequate tools like Excel for managing this process—there are serious implications, both from regulatory and organizational performance perspectives.
Regulatory Implications for C-Level Executives
| Risk | Description | Consequence |
|---|---|---|
| Regulatory Sanctions | Supervisors (e.g. ECB, DNB) require traceable, auditable, and consistent planning and execution. Excel lacks audit trails, version control, and user accountability. | Fines, remediation orders, public censure, or even leadership changes. |
| ICAAP/ILAAP Failure | Business plans must be linked to capital and liquidity planning. Poor integration (especially in Excel) makes alignment unclear. | Risk of failing Supervisory Review and Evaluation Process (SREP), leading to higher capital requirements. |
| Internal Governance Failures | Regulators assess governance effectiveness. Strategic misalignment between board and execution levels is a red flag. | Criticism in supervisory letters, lower trust in management. |
| BCBS 239 Non-Compliance | Regulatory principles require accurate, consistent, and timely risk and performance data. Excel cannot ensure this. | Non-compliance classification with remediation mandates. |
Operational and Strategic Implications
⚠️ Excel-Based Planning Risks
| Risk | Description | Consequence |
|---|---|---|
| Lack of Strategic Execution | Strategies defined by the board are not broken into goals, actions, or tracked KPIs. Execution becomes siloed or fails. | Missed targets, wasted budget, poor customer/staff satisfaction. |
| Data Silos and Inconsistency | Excel-based planning means each department may use its own sheet or version of reality. | Conflicting decisions, rework, loss of trust in reporting. |
| No Real-Time Insight or Adaptation | Excel is static and lacks real-time dashboards, alerts, or collaborative capabilities. | Delayed reactions to market, compliance, or risk signals. |
| Poor Accountability | Excel doesn’t assign owners, track updates reliably, or provide automated escalations. | Step owners go unmonitored; strategic gaps are not closed. |
| Inability to Support Audits or Reviews | Auditors and regulators need traceable documentation. Excel lacks workflow history, approvals, and logs. | Higher audit burden, costly remediation programs. |
Personal Risk for C-Level Executives
📉 C-Level Impacts of Strategic and Regulatory Failures
| Impact | How It Affects C-Level |
|---|---|
| Reputation Damage | Seen as outdated, reactive, or ineffective leaders—especially by investors, board, and regulators. |
| Accountability | Regulators now assess individual accountability (e.g., under Senior Managers Regime in UK or similar EU scrutiny). |
| Job Security | In systemic governance failures, regulatory pressure can lead to enforced leadership changes. |
| ESG and Digital Transformation Failures | Strategy that doesn’t cascade often results in underperformance on ESG, innovation, and transformation KPIs, which are now C-level scorecard items. |
Better Practice: What Regulators and Boards Expect
- Use modern, auditable tools for cascading strategy (e.g. OGSM platforms, enterprise performance systems).
- Ensure ownership, deadlines, and measurable KPIs at all levels.
- Provide real-time dashboards to board and regulators.
- Align all planning (strategy, risk, capital, compliance, transformation) in one connected framework.
Very simple example
Frequently asked questions
What is a GRC strategy in banking?
A GRC (Governance, Risk, and Compliance) strategy in banking is an integrated framework that helps financial institutions align their business objectives with regulatory requirements and risk management practices. It ensures that governance policies, risk mitigation efforts, and compliance protocols are embedded into everyday decision-making. A strong GRC strategy increases accountability, reduces operational risks, and strengthens audit readiness.
Why is Excel risky for bank planning?
Using Excel for strategic planning and execution tracking in banks introduces significant risks. Spreadsheets lack real-time collaboration, version control, audit trails, and structured accountability — all of which are critical in regulated environments. Errors can go unnoticed, approvals are difficult to trace, and progress reporting becomes fragmented. These weaknesses can compromise compliance, frustrate auditors, and lead to costly delays or misalignment.
How does OGSMsoftware.com support compliance?
OGSMsoftware.com is built for compliance in regulated industries like banking. It provides structured, traceable business planning and execution aligned with frameworks like ISO 27001 and ISAE 3000. All actions, strategies, goals, and KPIs are securely tracked in real time, with full visibility and audit logs. This ensures banks can demonstrate control, alignment, and accountability — satisfying internal governance teams, regulators, and external auditors alike.