Core Path · L3.6.10

Hedging the banking book

12 minIRRBBStructural hedgeMacro hedgeInterest rate swapsHedge accounting

Know these first

By the end you will be able to

  1. 1Explain how ALM uses interest rate swaps to hedge the banking book: the macro hedge on fixed-rate loans and the structural hedge on stable funding.
  2. 2Describe the structural hedge's rolling ladder and why it smooths income over years.
  3. 3Show on the bank's book what each hedge does to NII and to EVE, and why the two can pull in opposite directions.
  4. 4Outline hedge accounting: the accounting mismatch, fair value and cash flow hedges, portfolio hedging and the EU carve-out.

Why it matters

RiskAtoms Bank holds two sets of interest rate swaps that point in opposite directions: £19.2bn that pay a fixed rate and £16bn that receive one. A visitor might ask why the treasury does not just cancel them and save the fees. Take away the receive-fixed swaps and a 275bp fall in rates costs the bank £604.3m of net interest income in the first year instead of £263.3m, and its economic value test goes from a pass to a fail. Take away the pay-fixed swaps instead and it fails the same test from the other side. Each hedge answers a different question, and the answers only make sense together.

Core explanation

Two hedges, two jobs

Illustrative dataRiskAtoms Bank plc's banking book

The same £67bn balance sheet as Module 3.5, on one made-up reporting date, in pounds, with how each line reprices, its customer rate, a SONIA curve with Bank Rate at 4.00%, a £19.2bn macro hedge on the fixed-rate mortgages and a £16bn structural hedge. Tier 1 capital is taken as £3.5bn. The figures are round illustrative values, not any bank's data. Every lesson in Module 3.6 uses this book, so the figures agree.

This lesson uses the book's two hedges as they are. The swap rates when they were written are illustrative history, not market data.

A swap exchanges a fixed rate for a floating one on a notional amount (L1.7.04: Interest rate swaps). In the banking book it is ALM's main tool because it changes the rate behaviour of a block of the balance sheet without touching the customers. A pay-fixed swap turns fixed-rate assets into floating ones; a receive-fixed swap turns floating income into fixed. The book holds each swap as a fixed leg and a SONIA leg, so swaps add up like any other position in the gap, NII and EVE.

The macro hedge: fixed-rate mortgages

The bank lends £24bn of two- and five-year fixed-rate mortgages and funds them with deposits that reprice much sooner. The macro hedge pays fixed on 80% of the mortgages' expected repricing profile, quarter by quarter: £19.2bn at 3.9% and 3.0%, the swap rates when the loans were written. It stops at 80% because borrowers prepay (L3.6.08: Optionality in loans): if they prepay faster, the swaps stay and the bank is over-hedged. In parallel up the mortgages lose £1,069.6m of value and the swaps gain £755.6m.

The structural hedge: deposits and equity

The other side of the bank has money that does not reprice: the core current accounts of L3.6.09: Non-maturity deposits, paying about 0.5% whatever happens, and the equity, which pays no interest at all. Invested overnight, their income would rise and fall with Bank Rate one for one. The structural hedge invests £12bn of the core current accounts and the £4bn of equity in receive-fixed swaps, arranged as a five-year rolling ladder.

ExploreHow the ladder works

Click a box to see what happens there.

60 tranches

The £16bn is split into 60 equal monthly tranches of £266.7m, each a five-year receive-fixed swap written in a different month over the past five years.

The price of that stability is that the hedge lags the market both ways. When rates rose from near zero, ladders built in the low-rate years held income down for years; in a fall they hold it up. The table shows the second case: Bank Rate drops 275bp at once, but the ladder's yield drifts down over five years.

After a 275bp fallLadder yieldFixed incomeNet of the SONIA leg
Year 13.63%£580.6m+£325.6m
Year 23.39%£541.9m+£341.9m
Year 32.82%£451.2m+£251.2m
Year 42.29%£366.1m+£166.1m
Year 51.80%£287.4m+£87.4m

What the hedges do together

Run the book with each hedge on and off. Year-1 and three-year ΔNII are for the parallel shocks of 275bp; the outlier test is the worst of the six EVE shocks against 15% of Tier 1.

HedgesYear 1, −275bpYear 1, +275bp3 years, −275bpWorst ΔEVEOf Tier 1
No hedges−£241.6m+£233.0m−£1,280.0m−£80.7m (parallel up)2.30%
Macro hedge only−£604.3m+£595.7m−£2,025.9m−£771.6m (parallel down)22.05%
Structural hedge only+£99.4m−£108.0m−£411.0m−£1,012.9m (parallel up)28.94%
Both hedges (the book)−£263.3m+£254.7m−£1,156.9m−£257.2m (parallel up)7.35%
  • No hedges. The fixed-rate mortgages and the slotted deposits roughly offset in value: the worst ΔEVE is only 2.3% of Tier 1. But NII swings with rates because the deposits earn whatever Bank Rate pays.
  • Macro hedge alone. The mortgages now earn a floating rate, the natural offset is gone and the bank holds only the deposits' behavioural length. A fall of 275bp costs £604.3m in year 1 and the bank is an outlier, at 22.0%.
  • Structural hedge alone. Fixed income on top of fixed mortgages: the bank is long fixed-rate assets twice over and fails in parallel up, at 28.9%.
  • Both. The bank passes at 7.35%, and its NII still rises with rates (+£254.7m at +275bp) and falls with them, by less than half the macro-only swing.

Netted, the two hedges leave a pay-fixed position of about £3.2bn, at different tenors. In practice a treasury nets such flows internally and trades only the difference with the market. Each hedge is still sized on its own block, because each protects something different: the margin on fixed-rate lending from the day it is priced, and the income on stable funding over the cycle. L3.6.11: Funds transfer pricing shows how transfer pricing hands each result to its owner.

Hedge accounting in outline

A swap is a derivative, measured at fair value with changes in profit and loss. Mortgages and deposits are held at amortised cost and show no change at all. In parallel up the macro hedge would book a gain of £755.6m and the structural hedge a loss of £932.2m, while the items they hedge stay still: an accounting mismatch that makes profit swing although the bank's economic position barely moved. Hedge accounting realigns the timing.

  • Fair value hedge. The hedged item is also revalued for the hedged risk, so the two changes offset in profit and loss and only ineffectiveness is left. For a portfolio such as the mortgages, IAS 39's portfolio fair value hedge of interest rate risk lets the bank analyse the portfolio into repricing time periods by expected repricing dates, designate an amount of assets (not a net amount) in each, and show the hedged item's revaluation as a separate line.
  • Cash flow hedge. The derivative hedges variable future cash flows, such as interest on floating-rate assets. The effective part of its change in value waits in other comprehensive income, the cash flow hedge reserve, and moves to profit and loss as the hedged interest does.
  • Deposits are the hard part. IAS 39 does not let a liability repayable on demand be a hedged item in a fair value hedge for any period beyond the earliest date it can be withdrawn, so core deposits cannot be designated for their behavioural life. Banks in the European Union can use the EU carve-out, which lets them include core deposits in portfolio fair value hedges and does not treat under-hedging as ineffectiveness. Others have to find a different hedged item.
  • IFRS 9 and what comes next. IFRS 9 brought a new general hedge accounting model in 2013, but banks may keep applying the IAS 39 portfolio hedge model for macro hedging. In December 2025 the IASB published an exposure draft, Risk Mitigation Accounting, a model for dynamically managed repricing risk, with comments due by 31 July 2026.

Sort itFair value hedge or cash flow hedge?

Decide which hedge accounting model fits each swap.

  • A pay-fixed swap on a portfolio of fixed-rate mortgages

  • A receive-fixed swap that fixes the interest on floating-rate corporate loans

  • A swap that turns the bank's own fixed-rate senior bond into floating

  • A pay-fixed swap that locks the cost of funding the bank will roll over next year

  • A receive-fixed swap on core deposits, under the EU carve-out

The formal version

The structural hedge has N=60N = 60 tranches of notional AA, tranche kk maturing at tkt_k with fixed rate rkr_k. A tranche that matures is replaced at the new five-year rate rnewr^{\text{new}}. The ladder's average rate tt years from now, and the swaps' net income over year one, are:

rˉ(t)=1N∑k=1N[ 1(tk>t) rk+1(tk≤t) rnew]I1=∑kA[rk min⁡(tk,1)+rnew (1−min⁡(tk,1))]⏟fixed leg  −  NA rˉON⏟SONIA legΔI1≈− NA ΔrON⏟resets within 3 months  +  Δr5∑tk<1A (1−tk)⏟tranches rolled this year\begin{aligned} \bar r(t) &= \frac{1}{N}\sum_{k=1}^{N}\Big[\,\mathbf 1(t_k > t)\, r_k + \mathbf 1(t_k \le t)\, r^{\text{new}}\Big] \\ I_1 &= \underbrace{\sum_{k} A\big[r_k\,\min(t_k,1) + r^{\text{new}}\,(1-\min(t_k,1))\big]}_{\text{fixed leg}} \;-\; \underbrace{N A\, \bar r_{\text{ON}}}_{\text{SONIA leg}} \\ \Delta I_1 &\approx \underbrace{-\,NA\,\Delta r_{\text{ON}}}_{\text{resets within 3 months}} \;+\; \underbrace{\Delta r_5 \sum_{t_k<1} A\,(1-t_k)}_{\text{tranches rolled this year}} \end{aligned}

With today's ladder rˉ(0)=3.60%\bar r(0) = 3.60\% and rnew=4.29%r^{\text{new}} = 4.29\%. After a 275bp fall the fixed leg still earns £580.6m\text{£}580.6\text{m} in year 1 while the SONIA leg costs much less, so the swaps add £325.6m\text{£}325.6\text{m} to NII. For hedge accounting, with ΔV\Delta V the change in fair value:

Fair value hedge:P&L=ΔVswap+ΔVitemhedged risk  =  ineffectivenessCash flow hedge:∣OCI reserve∣=min⁡(∣∑ΔVswap∣,  ∣∑ΔVhedged flows∣)P&L=ΔVswap−Δ(OCI reserve)\begin{aligned} \text{Fair value hedge:}\quad \text{P\&L} &= \Delta V_{\text{swap}} + \Delta V_{\text{item}}^{\text{hedged risk}} \;=\; \text{ineffectiveness} \\ \text{Cash flow hedge:}\quad \big|\text{OCI reserve}\big| &= \min\Big(\big|\textstyle\sum\Delta V_{\text{swap}}\big|,\; \big|\textstyle\sum\Delta V_{\text{hedged flows}}\big|\Big) \\ \text{P\&L} &= \Delta V_{\text{swap}} - \Delta(\text{OCI reserve}) \end{aligned}

Try it

Move rates, resize the structural hedge and switch the mortgage hedge on or off. The chart shows the ladder rolling month by month; the readouts are the whole bank's NII and outlier test.

Try itRoll the structural hedge through a rate move

Mortgage hedge

0.0%1.0%2.0%3.0%0y1y1y2y2y3y3y4y4y5y5yYears after the move (one tranche of 60 matures each month)
Ladder's average fixed rateOvernight rate (the swaps' SONIA leg)New five-year rate the ladder rolls into
Year-1 ΔNII, the bank−£263.3m
Worst ΔEVE (Parallel up)7.35% of Tier 1
Year-2 ΔNII−£391.0m
Year-3 ΔNII−£502.6m
Ladder yield in year 13.63%
Hedge's net swap income, year 1+£325.6m
Worst ΔEVE−£257.2m
Outlier line£525m

After a fall, the ladder keeps earning its old fixed rates and only one-sixtieth of it reprices each month, so income drifts down over five years instead of dropping at once. Take the structural hedge to zero with the macro hedge on and the bank fails the outlier test in parallel down; push it to £24bn and it fails in parallel up. The hedge has a right size, and it is not the biggest one.

Worked example

The ALCO paper on the two hedges

Should the bank keep both hedges?

Step 1 of 5
  1. 1

    Unhedged

    Without swaps NII today is £1,522.0m. At −275bp year-1 NII falls £241.6m and £1,280.0m over three years. Value is well balanced: worst ΔEVE 2.30% of Tier 1.

What the treasurer notes

The two hedges partly offset; together they pass the outlier test at 7.35% and more than halve the year-1 NII loss in a 275bp fall compared with the macro hedge alone. Size them to their blocks, net them internally and trade the difference.

Regulatory lens

Risk management first. The EBA's 2022 guidelines on IRRBB say banks using derivatives to mitigate IRRBB need the knowledge and expertise to do so, should understand the accounting effects of their hedges but that “the accounting treatment should not drive their risk management approach”, and should monitor how hedging strategies evolve. The standard's NII and EVE measures include the hedges, as this book does. The supervisory detail is M4.5: Liquidity and IRRBB regulation.

Accounting. Hedge accounting sits in IAS 39 and IFRS 9; the EU endorsed IAS 39 with the carve-out by Commission Regulation (EC) No 2086/2004 of 19 November 2004. IFRS 9 in depth comes in M4.7: Accounting for risk.

Spark Atoms

Spark AtomThe swap that lost £932m and did its job
In the parallel up shock the structural hedge loses £932.2m of value, more than a quarter of Tier 1, while the bank's NII rises. Nothing is broken: the swaps receive a fixed rate on money that would otherwise have earned the new, higher overnight rate. The loss in value is the income the bank gave up to make that income certain.
Spark AtomTwenty years of a temporary fix
The EU carve-out was meant to be temporary: endorsing IAS 39, the European Commission called it “purely temporary” and expected the IASB to amend its hedge accounting rules by September 2005. The carve-out regulation dates from November 2004; the IASB's exposure draft of a model for dynamically managed interest rate risk came out in December 2025.

Key takeaways

  • ALM hedges the banking book with swaps: pay fixed to turn fixed-rate loans floating, receive fixed to turn the income on stable funding fixed.
  • The macro hedge pays fixed on 80% of the mortgages' expected profile (£19.2bn); it stops short because borrowers prepay.
  • The structural hedge invests £16bn of core current accounts and equity in a five-year ladder of 60 tranches; its yield (3.60% today) moves a sixtieth a month.
  • Each hedge alone fails the outlier test (22.0% and 28.9%); together 7.35%, with the year-1 NII loss at −275bp cut from £604m to £263m.
  • Hedge accounting fixes the timing mismatch: fair value hedges for value, cash flow hedges for cash flows; core deposits need the EU carve-out or another hedged item.

Reaction

Check what stuck

Question 1 · objective 2

A bank invests £12bn of core current accounts in a five-year receive-fixed ladder of 60 equal monthly tranches. How much matures and is reinvested each month, in £m?

£m

Question 2 · objective 2

A structural hedge yields 2.0% on average. Over the next year a fifth of it matures and is replaced at 4.5%. What does the whole ladder yield after that year, in %?

%

Question 3 · objective 1

Which swap turns the fixed income on a portfolio of five-year fixed-rate mortgages into floating income?

Question 4 · objective 4

In a fair value hedge, the pay-fixed swap gains £50m of fair value. The hedged mortgages lose £46m of fair value for the hedged interest rate risk. What reaches profit and loss as ineffectiveness, in £m?

£m

Question 5 · objective 3

Without the structural hedge, RiskAtoms Bank's year-1 NII falls £604.3m at −275bp; with it, £263.3m. Yet in parallel up the structural hedge loses £932m of value. Why is that not a failure?

Glossary

Macro hedge
Macro hedge: swaps that hedge a whole portfolio of similar items, such as fixed-rate mortgages, against its expected repricing profile rather than loan by loan.
Structural hedge
Structural hedge: receive-fixed swaps that turn the income on stable, rate-insensitive funding (core current accounts and equity) from overnight into a rolling multi-year fixed rate.
Rolling ladder
Rolling ladder: a hedge split into equal tranches with staggered maturities; each month one matures and is replaced at that day's rate, so the average rate moves slowly.
Pay-fixed swap
Pay-fixed swap: the bank pays a fixed rate and receives a floating rate (SONIA). It gains when rates rise.
Receive-fixed swap
Receive-fixed swap: the bank receives a fixed rate and pays a floating rate. It gains when rates fall.
Accounting mismatch
Accounting mismatch: when a hedge is measured at fair value through profit and loss but the item it hedges is held at amortised cost, so profit swings although the bank's economic position does not.
Fair value hedge
Fair value hedge: hedge accounting in which the hedged item's change in value for the hedged risk is also recognised, so it offsets the derivative's change in profit and loss.
Cash flow hedge
Cash flow hedge: hedge accounting in which the effective part of the derivative's change in value goes to other comprehensive income (the cash flow hedge reserve) and reaches profit and loss when the hedged cash flows do.
Hedge ineffectiveness
Hedge ineffectiveness: the part of the derivative's change in value that the hedged item does not offset. It goes to profit and loss.
EU carve-out
EU carve-out: the European Union's 2004 endorsement of IAS 39 without certain hedge accounting requirements, so banks can include core deposits in portfolio fair value hedges and need not book ineffectiveness when under-hedged.

Deep Dives & Origins

Deep Dives

  • IFRS Foundation, IAS 39 Financial Instruments: Recognition and Measurement, paragraphs 81A, 89A and AG114 to AG132 (portfolio fair value hedge of interest rate risk). Advanced.
  • EFRAG, DRM: issues in relation to the carve-out, TEG paper 09-03, October 2021. Advanced.
  • Deloitte UK, Structural hedging: accounting considerations, blog, August 2026. Intermediate.

Origins

  • IFRS Foundation, IAS 39 Financial Instruments: Recognition and Measurement, 2025 issued standard.
  • EFRAG, DRM: issues in relation to the carve-out and Dynamic risk management: feedback on the EU carve out, TEG issues papers, October 2021 and March 2022.
  • Commission Regulation (EC) No 2086/2004 of 19 November 2004 amending Regulation (EC) No 1725/2003 as regards IAS 39, Official Journal of the European Union; European Commission, Accounting standards: Commission endorses IAS 39, press release, 19 November 2004.
  • BDO, IASB publishes exposure draft Risk Mitigation Accounting, December 2025.
  • Deloitte UK, Structural hedging: accounting considerations, 11 August 2026.
  • European Banking Authority, Guidelines on IRRBB and CSRBB, EBA/GL/2022/14, 20 October 2022, paragraphs 36, 38 and 45.

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