ICAAP Path Cycle 1 + 2 substantiated
ICAAP
SUPERVISOR
DEFENSIBLE
ICAAP / Supervisor-defensible geopolitical scenarios

The 2026 ECB thematic stress test treats geopolitical risk as a transmission mechanism, not as scenario garnish layered over the existing risk lines.

Supervisor · SSM
Submission · 2026 cycle open

The supervisor has been signalling this since the 2025 cycle. The submission window for the 2026 cycle is open. The analytical substrate most banks at this altitude do not yet have is the one that lets the four-step response — materiality, quantification, framework enhancement, BAU integration — compose without rebuilding the risk infrastructure underneath.

01 / LEVEL ONE
THE SIGNAL

The configuration substrate active now, in the supervisor's grammar — not the analyst's translation of it.

Bearing reading the configuration substrate at the altitude SSM banks operate in. The reads are presented at production cadence — the same output the engine produces against an institutional buyer's named portfolio under contracted deployment.

Cadence · daily
Refresh · 09:00 CET
Trace · every claim
01.1
SUPERVISOR
PRESSURE

The 2026 ECB thematic stress test requirement names what banks operating at SSM altitude have been signalling internally for several cycles: geopolitical risk has stopped being scenario garnish layered over the existing risk lines and has become a transmission mechanism that operates through credit, market, and operational risk.

The supervisor is no longer asking banks to demonstrate that geopolitical scenarios have been considered; the supervisor is asking banks to demonstrate that geopolitical configurations have been characterised at quantification depth, with cascade composition through the bank's specific portfolio structure, and with the substrate available for supervisor review at the rigour the supervisor's own quant team operates in.

What follows is Bearing reading the configuration substrate currently active in the global environment at the altitude this requirement operates against.

The signals below are presented as Bearing reading them in the supervisor's grammar, not as the analyst's interpretation translated for the supervisor.

01.2
LIVE
CONFIGURATION
SUBSTRATE

22 MAY 2026
09:00 CET
Live configuration substrate 4 active · p < 0.05
PHM-CMP-0089 Escalating · Day 47
Hormuz Compound
Phase × cluster severity at p < 0.05 against corpus baseline. Cluster composition: energy infrastructure (oil refining capacity, LNG terminal exposure), insurance underwriting (marine and offshore facility coverage), banking sector exposure (financing to integrated energy operations across the corridor).
Trace · 2008 Strait pricing + 2020 shipping cascade + 2022 energy infrastructure
PHM-CMP-0102 Absorbing · Day 12
Iran-Russia-Taipei integrated
Cross-compound configuration operating across three structurally interconnected substrates. The cross-transmission produces compound effects that single-substrate readings miss. Cluster composition: sovereign-bank nexus exposure, integrated energy operations, cross-border supply chain.
Trace · 2008 sovereign cascade + 2020 supply chain cascade + 2022 integrated energy
PHM-CMP-0114 Escalating · Day 23
Sovereign-bank nexus pressure
European-periphery sovereign exposure cascade through the bank-sovereign nexus. Cluster composition: sovereign bond holdings at SSM banks, sovereign-guaranteed lending, sovereign-related counterparty exposure.
Trace · 2008 sovereign cascade + 2011 European sovereign + 2022 sovereign refinancing
PHM-CMP-0127 Absorbing · Day 8
Energy infrastructure transmission
European energy infrastructure cascade through the renewable transition and the integrated gas-network exposure. Cluster composition: utility sector exposure, gas transmission operator exposure, renewable developer financing.
Trace · 2022 European energy cascade + 2020 utility cascade

Hover any configuration anchor to reach the corpus precedent. Hover any cluster element to reach the primary substrate. The trace defends the read; the trace operates as the architectural substrate of the cannot-be-wrong commitment.

01 / CLOSE The configuration substrate is what Bearing reads continuously. The next level composes the cascade — how these configurations transmit through the bank's specific portfolio structure in the language ICAAP requires. Continue to Level 02
02 / LEVEL TWO
THE CASCADE

How the signal cascades through the bank's portfolio in the language ICAAP requires.

The FTI four-step response rendered as Bearing operating against the SSM bank archetype. Materiality, quantification, framework enhancement, BAU integration — composed at production cadence in the supervisor's grammar.

Structural · FTI 4-step
Grammar · supervisor's
Cycle · SSM 2026
02.0
CASCADE
COMPOSITION

The cascade composition is what most banks compose internally over weeks of risk-team work. The analyst characterises the configuration's transmission through the credit risk line; the market risk team composes the parallel transmission through the trading book; the operational risk function characterises the third transmission; the framework team integrates the three into the ICAAP appendix. The composition is defensible if the team is good and has time; the composition is not continuously refreshed; the composition is not in the supervisor's grammar by default — it gets translated.

What follows is Bearing composing the cascade against the SSM bank archetype, with the FTI four-step response operating as the structural composition the supervisor's grammar requires.

STEP 01 MATERIALITY
ASSESSMENT

The supervisor requires materiality identification: which configurations measurably affect the named portfolio.

Bearing composes materiality through continuous compound-configuration screening against the bank's exposure surface. Materiality is measured, not narrated. The screening operates at phase × cluster severity at p < 0.05 against the 1973 corpus baseline. The configurations that surface at material altitude are the configurations whose cascade through the bank's portfolio structure crosses the materiality threshold at statistical significance — not the configurations the analyst's narrative judgment promotes to material status.

SSM bank archetype · materiality screening Live · Engine output
Material
PHM-CMP-0089Hormuz Compound
Cascade: energy infrastructure exposure €2.4B notional, insurance underwriting counterparty €840M, energy-integrated corporate lending €1.6B.
Phase 3 escalating p < 0.01
Material
PHM-CMP-0102Iran-Russia-Taipei integrated
Cascade: sovereign-bank nexus exposure €3.2B sovereign holdings, cross-border supply chain corporate €2.1B, integrated energy operations financing €940M.
Phase 2 absorbing p < 0.001
Material
PHM-CMP-0114Sovereign-bank nexus pressure
Cascade: European-periphery sovereign exposure €4.8B sovereign holdings, sovereign-guaranteed lending €1.2B, sovereign-related counterparty €680M.
Phase 3 escalating p < 0.001
Below threshold
PHM-CMP-0127Energy infrastructure transmission
Cascade: utility sector exposure €680M, gas transmission operator exposure €340M. Surfaced for monitoring; not material under current regime characterisation.
Phase 2 absorbing p = 0.08
Materiality assessment becomes a property of the substrate, not an analyst's narrative judgment. The threshold is statistical, traceable, and reproducible.
STEP 02 RISK
QUANTIFICATION

Quantification in the supervisor's own math. Not a translation of the bank's internal scoring.

Bearing composes quantification through HMM regime emission parameters and Kalman state estimates the supervisor's quant team recognises. The statistical separation tests verify independently. Cohen's d, p-values, innovation variance ratios — the discipline the supervisor operates in.

PHM-CMP-0089 Hormuz Compound Quantification

Credit risk transmission

Probability of default uplift, 1y energy exposure · escalating regime+180 bps
Probability of default uplift, 1y energy exposure · base case+95 bps
Loss given default, energy exposure · resolution outcome A+12 pp
Loss given default, energy exposure · resolution outcome B+18 pp
Expected loss uplift, 1y total€31M – €58M

Market risk transmission

Trading book VaR uplift, 1y energy-related instruments · HMM regime+28%
Statistical floor · Kalman re-init at corpus boundaryno projection beyond precedent

Operational risk transmission

Operational loss uplift, 1y infrastructure · escalating cascade€4M – €11M
Trace2020 shipping + 2022 EU energy
PHM-CMP-0102 Iran-Russia-Taipei integrated Quantification

Credit risk transmission

PD uplift, sovereign-related counterparty · absorbing regime+95 bps
LGD, sovereign-guaranteed lending+8 pp
Expected loss uplift, 1y total€42M – €71M

Market risk transmission

Sovereign-bond VaR uplift, 1y · HMM regime+22%
Cross-border counterparty VaR uplift+18%

Operational risk transmission

Cross-border supply chain operational loss · absorbing cascade€2M – €7M
PHM-CMP-0114 Sovereign-bank nexus pressure Quantification

Credit risk transmission

PD uplift, sovereign-periphery exposure · escalating regime+220 bps
LGD, sovereign-guaranteed lending+15 pp
Expected loss uplift, 1y total€68M – €112M

Market risk transmission

Sovereign-bond VaR uplift, 1y · HMM regime+34%
The quantification is in the supervisor's grammar by default. No re-keying, no re-writing for the appendix. The HMM regime emission parameters and Kalman state estimates compose directly into the supervisor's quantification framework.
STEP 03 FRAMEWORK
ENHANCEMENT

The substrate plugs in under the existing framework. The framework does not rebuild around the substrate.

Bearing composes framework enhancement as the architectural substrate the existing ICAAP framework plugs onto. The configuration substrate produces the inputs the framework's existing risk-aggregation methodology absorbs. The bank's economic capital model receives the quantification output in the format the model already operates against. The substrate plugs in under the framework; the framework does not rebuild around the substrate.

Existing ICAAP framework
Bearing substrate
Risk identification
Continuous compound configuration screening
Materiality assessment
Phase × cluster severity at p < 0.05
Risk quantification
HMM emission parameters + Kalman state estimates
Risk aggregation
Bank's existing aggregation methodology — unchanged
Capital adequacy
Bank's existing capital adequacy framework — unchanged
ICAAP appendix
Output composes into the appendix's existing register
Output composes into Appendix B.3 in the register the submission requires. No re-keying. The substrate plugs in under the existing framework rather than replacing it.
STEP 04 BAU
INTEGRATION

The ICAAP appendix is a snapshot of an engine that did not stop running when the analyst stopped looking.

Bearing operates continuously by architectural design. The phase × cluster matrix surfaces daily what warrants attention. The cascade composition refreshes against the live configuration substrate. The threshold-crossing alerts deliver through the bank's working channels — email, Microsoft Teams, Slack, authenticated API endpoint.

Continuous Configuration screening, phase characterisation, severity tracking.
Daily Matrix recomposition at 09:00 CET. Phase × cluster severity refresh.
Event-driven Threshold-crossing alerts on configuration phase transitions, severity escalations, cascade compositions that cross materiality.
Weekly Committee-grade rendering of the week's substantive substrate changes.
Quarterly ICAAP appendix composition for the submission cadence.
Annual ICAAP framework review against the substrate's evolution; corpus extension cycles where the bank's portfolio surfaces gaps in the canonical.
Phase progression runs daily. Named compounds escalate, absorb, resolve under live frequency. The ICAAP appendix is a snapshot of an engine that did not stop running when you stopped looking.
02 / EXTENDED READ

This is what a full reverse stress test read looks like against a German SSM archetype.

Read the German SSM artefact
02 / CLOSE The cascade composition above is the engine operating against the SSM bank archetype. The next level composes the read against your named institution's specific portfolio. Continue to Level 03