For debt instruments that are measured at FVOCI under IFRS 9, the ECL impairments do not reduce the carrying amount in the balance sheet, which remains at fair value. Instead, an impairment loss in profit or loss is recognised against OCI as accumulated impairment amount, with no impact on the total equity (as the impairment loss is recognized in profit or loss and OCI increases for the same amount) and, consequently, no impact on the CET1 capital. Therefore it is unclear whether these ECL impairments qualify as specific credit risk adjustments, and how the original exposure pre-conversion for the FVOCI debt instrument is to be calculated. For example: N: debt instrument is purchased at 100 and measured at FVOCI N+1: fair value decreases to 95 N+2: fair value remains 95 and ECL impairment of 3 is recognized Accounting entries N: Dt FVOCI debt instrument (asset) 100 Ct Cash -100 Accounting entries N+1: Dt OCI (equity) 5 Ct FVOCI debt instrument (asset) -5 Accounting entries N+2: Dt ECL impairment loss (profit or loss) 3 Ct OCI (equity) -3 => At N+2, the carrying amount of the asset is 95, the recorded ECL impairment decreases profit or loss with 3, and OCI had been increased with 3, hence there is no impact on CET-1 capital. The following options are possible: 1. original exposure pre-conversion factors = 95 (=carrying amount) specific credit risk adjustment = 0 => exposure net of value adjustments = 95 2. original exposure pre-conversion factors = 95 (=carrying amount) specific credit risk adjustment = -3 => exposure net of value adjustments = 92 3. original exposure pre-conversion factors = 98 (=carrying amount + ECL impairment) specific credit risk adjustment = -3 => exposure net of value adjustments = 95