Know these first
- L2.5.02: Return distributions
By the end you will be able to
- 1Build a loss record: its three dates, gross loss, recoveries, net loss and flags.
- 2Explain how the collection threshold and the choice of date change what the data says.
- 3Read the shape of operational losses from a histogram and a concentration curve, and say why the tail decides the total.
- 4Say what external loss data and near misses add, and what their weaknesses are.
Why it matters
Half of RiskAtoms Bank's operational losses are booked within 50 days of the event. Yet 73% of the money is booked more than a year after the event happened. The typical loss is £31,976; the largest is £82m. Loss data is the only hard evidence an operational risk team has, and almost every number in it depends on how it was collected.
Core explanation
What a loss record holds, and why each field matters
Internal loss data is the bank's diary of things that went wrong. The business records each event; the second line checks it is complete (L3.7.02: The operational risk framework). Here are two records from the book:
Dormant-account internal fraud
Operations team leader diverted dormant-account balances to accounts they controlled for 30 months
- Record
- OL-2022-010
- Event type
- Internal fraud
- Bank's category
- Fraud
- Business line
- Retail banking
- Occurred
- 2019-04-15
- Discovered
- 2021-11-08
- Accounted (booked)
- 2022-01-31
- Gross loss
- £7,600,000
- Insurance recovered
- £3,000,000
- Other recoveries
- £900,000
- Net loss
- £3,700,000
Flags: none
Business email compromise fraud
Business email compromise: phished relationship manager mailboxes redirected client payments; the bank reimbursed
- Record
- OL-2025-042
- Event type
- External fraud
- Bank's category
- Cyber and information security
- Business line
- Commercial banking
- Occurred
- 2025-04-02
- Discovered
- 2025-04-09
- Accounted (booked)
- 2025-04-30
- Gross loss
- £6,200,000
- Insurance recovered
- £0
- Other recoveries
- £1,100,000
- Net loss
- £5,100,000
Flags: none
Gross, recoveries and net
The gross loss includes direct charges, write-downs, provisions, settlements and costs such as external legal fees and repairs. It leaves out lost income, insurance premiums and money spent on improvements afterwards. A recovery is a later inflow linked to the event; it counts only once received. Over ten years the bank's operational losses were £259.6m gross, with £7.4m back from insurers and £11.7m from other recoveries, leaving £240.5m net. 321 of the 935 events had some recovery.
The three dates
Each record carries a date of occurrence, a date of discovery and a date of accounting. The gaps between them differ hugely by type:
| Event type | Events | Happened → found | Found → booked | Happened → booked | Money booked > 1 year after |
|---|---|---|---|---|---|
| Clients and products | 117 | 583 | 136 | 749 | 100% |
| Internal fraud | 13 | 240 | 74 | 332 | 46% |
| Employment and safety | 51 | 78 | 167 | 249 | 67% |
| Execution and process | 307 | 19 | 22 | 45 | 39% |
| External fraud | 370 | 7 | 29 | 39 | 0% |
| Physical assets | 26 | 1 | 42 | 43 | 0% |
| Disruption and systems | 51 | 1 | 31 | 33 | 0% |
| All types | 935 | 50 | 73% |
Outages and floods are found the same day. External fraud is booked in about 39 days. Conduct losses take 749 days in the middle case, and the big ones far longer: the mis-sold packaged accounts were first sold in 2012, found 2,023 days later and provided for 167 days after that. Each date answers a different question. Accounting: what hit the profit and loss account this year? Occurrence: when did the control fail? Discovery: how fast do we find our failures? Dated by occurrence, £120.8m of the losses belong to 2012, before the data even starts. And recent years always look better than they are: losses that occurred in 2025 total £27.5m so far, but some have not been found yet.
Thresholds, near misses and boundary events
The bank records every loss from £10,000 gross, below the £20,000 the book uses for the loss component (Basel sets €20,000; the book keeps the round number in pounds), so it learns from small failures. The threshold barely changes the total: moving to £20,000 drops 27% of the events but only 1.2% of the money; at £100,000 it keeps 14% of the events and 91% of the money. Around the losses sit other records:
- 131 near misses, with a potential loss the bank estimates at £54.9m in all. The 2021 Basel principles list near misses in the event data set.
- 38 rapidly recovered losses (£1.47m gross), a convention of this book.
- 41 credit-boundary events (£7.3m), recorded but left out, and 26 market-related ones (£5.2m), counted in (L3.7.01: What operational risk is).
- One grouped event in two records: the redress programme's first provision (£82m, 2018-02) and its top-up (£38m, 2019-07).
The shape: many small losses, a few that decide everything
A histogram (M-D02: Histograms and empirical distributions) of the 935 losses on size bands shows the problem. Each band is a few times wider than the one before, so this compares shares, not densities:
86% of the events are under £100,000 and make up 9% of the money. The 4 losses of £10m or more are 0.4% of the events and 69% of the money. That is a fat right tail (M-C08: Skewness and fat tails): the mean loss, £277,676, is 8.7 times the median. The concentration curve shows how fast the largest events take over:
The largest event is 34% of ten years' losses, the largest five 72%, the largest ten 81%. The other 925 events share what is left. This is why ten years of a bank's own data says little about the next 1-in-100-year loss, and why external data and scenarios exist.
External loss data
External loss data comes in two kinds. A consortium pools anonymised records from its members under one reporting standard. ORX, which calls itself the largest operational risk association in financial services, says its global banking loss data service has more than 80 participating banks and more than a million loss events; its June 2026 report counted more than 62,000 events in 2025 alone, with gross losses above €13bn. Public data collects losses reported in the news, court records and regulators' notices. Guess each answer before you open it:
What external data is good for, and where it misleads
Illustrative dataRiskAtoms Bank plc's operational risk book
The same £67bn bank as Modules 3.5 and 3.6, at 31 December 2025, in pounds: ten years of internal loss events of £10,000 or more (2016–2025), an RCSA of 17 key risks and 29 controls, ten key risk indicators over 24 months, seven workshop scenarios and five important business services. Every event, person, supplier and figure is made up for teaching; none is any bank's data. The same book runs through every lesson in Module 3.7, so the figures agree.
The book holds internal data only. The external figures above are ORX's published totals, dated as stated; no external records are added to the book.
The formal version
Each record's net loss is shown in full:
For the dormant-account fraud: .
The empirical distribution (M-D02: Histograms and empirical distributions) of the gross losses gives the share at or below any size:
Concentration is about the money, so from here the are net losses, and it needs one new piece of notation: the losses sorted from largest to smallest. Build it one step at a time:
A thin-tailed set of losses would need far more than ten events to reach 81%. With mean and median , a ratio far above 1 is the quickest sign of right skew (M-C08: Skewness and fat tails).
Try it
Rebuild the bank's ten years. Date the losses by when they were booked, happened or found; raise the collection threshold; leave out the redress programme. Which choice changes the picture most?
Try itLoss data lab
Date each loss by
The redress programme (£120m in two provisions)
Illustrative book: operational losses only (no near misses or credit-boundary events). The years show 2016–2025; losses dated earlier are counted in “before 2016”. Date by occurrence and the redress programme moves to 2012, before the window; leave it out and 2018 looks like any other year. Raise the threshold and watch how little money each step removes.
Worked example
From 1,107 records to the loss component
The capital rules use ten years of losses (L3.7.07: Measuring frequency and severity). The operational risk team builds that data set from the book, one filter at a time. Predict each count before you open the step.
Five filters
Step 1 of 5- 1
Start with every record
1,107 records over the ten accounting years 2016–2025: losses, near misses and boundary events.
Regulatory lens
Under the standardised approach, a bank's loss data can set its capital through the loss component, so OPE25.12 to 25.35 set strict rules: a €20,000 threshold (supervisors may raise it to €100,000 for larger banks), the three dates with the accounting date for the data set, gross and net loss, recoveries only once received, credit-related losses out and market-related ones in, grouping of related losses, independent review of the data, ten years of history, and yearly disclosure of the losses net of recoveries. The 2021 Basel principles add near misses and, where feasible, external data. The capital itself is in M4.4: Counterparty, operational and large exposures.
Spark Atoms
Spark AtomThe largest public loss of 2024
Spark AtomA loss you cannot book yet
Key takeaways
- A loss record holds three dates, the gross loss, insurance and other recoveries, the net loss, the event type, the business line, the cause and flags.
- The date decides the story: half the bank's losses are booked within 50 days, yet 73% of the money is booked over a year after the event. Basel uses the accounting date.
- Thresholds change the count far more than the money: £20,000 instead of £10,000 drops 27% of events and 1.2% of losses.
- Operational losses are fat-tailed: the mean is 8.7 times the median, the largest event is 34% of ten years and the largest ten 81%.
- External data, from a consortium or public reports, shows losses a bank has not had yet; it must be scaled and judged for relevance, and public data over-represents large events.
Reaction
Check what stuck
Question 1 · objective 1
The dormant-account internal fraud cost £7.6m gross. Insurers paid £3.0m and £0.9m was recovered from the fraudster's accounts. What is the net loss, in £m?
Question 2 · objective 2
Which date does the Basel loss data set use to place a loss in a year?
Question 3 · objective 2
RiskAtoms Bank collects from £10,000. If it collected from £20,000 instead, what share of its 935 operational loss events would it no longer record, in %?
Question 4 · objective 3
The median gross loss is £31,976 and the mean is £277,676. What does that say about the distribution?
Question 5 · objective 4
What is the main weakness of loss data from public reports, such as news of fines and settlements?
Glossary
- Internal loss data
- Internal loss data: the bank's own record of its operational loss events, collected above a threshold.
- External loss data
- External loss data: loss events at other firms, from a data-sharing consortium (anonymised, contributed by members) or from public reports.
- Loss data consortium
- Loss data consortium: banks that share anonymised loss records under a common standard so that each can see losses it has not yet had.
- Collection threshold
- Collection threshold: the gross loss above which every event must be recorded. Basel's minimum for the loss component is €20,000; banks often collect from lower.
- Date of occurrence
- Date of occurrence: when the event happened or, for a long-running one, began.
- Date of discovery
- Date of discovery: when the bank found out about it.
- Date of accounting
- Date of accounting: when the loss, reserve or provision was first booked in the profit and loss account. The Basel loss data set uses this date.
- Gross loss
- Gross loss: the loss before any recoveries.
- Recovery
- Recovery: a later, separate inflow linked to the event, such as an insurance payout or funds recalled from a fraudster's bank. It counts only once received.
- Net loss
- Net loss: gross loss less recoveries.
- Near miss
- Near miss: an event that could have caused a loss but did not. Recorded for learning; not a loss.
- Rapidly recovered loss
- Rapidly recovered loss: in this book, a loss recovered in full within five working days. Recorded, net loss zero.
- Grouping
- Grouping: losses from one root cause, such as several provisions for one mis-selling programme, are linked as one event even when booked in different years.
Deep Dives & Origins
Deep Dives
- Basel Committee on Banking Supervision, Basel Framework, OPE25 Standardised approach, paragraphs 25.12 to 25.35 (minimum standards for loss data), BIS. Intermediate.
- ORX, Banking Operational Risk Loss Data Report 2026, ORX, June 2026 (headline figures public, full report for members). Intermediate.
Origins
- Basel Committee on Banking Supervision, Basel Framework, OPE25 Standardised approach, paragraphs 25.12 to 25.35, BIS, version in force from 1 January 2023 (last updated 5 July 2024).
- Basel Committee on Banking Supervision, Revisions to the Principles for the Sound Management of Operational Risk, BIS, March 2021, paragraph 35(b).
- ORX, “Global Banking Loss Data Service”, orx.org, accessed November 2026.
- ORX, “Banking Operational Risk Loss Data Report 2026”, orx.org, June 2026.
- ORX News, “Top 5 ORX News Losses of 2024”, orx.org, 23 January 2025.
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