In a decisive move to fortify its financial system, the National Bank of Angola (BNA) has recalibrated its capital defense strategy for the nation’s most critical banks. Effective January 2026, only six commercial banks will be required to hold mandatory additional capital reserves, a significant shift from the previous framework. This policy targets institutions deemed “Domestic Systemically Important Banks” (D-SIBs), a designation reserved for entities whose failure could trigger widespread economic contagion.
The six banks subject to the new requirements are: Banco de Fomento Angola (BFA), Banco Angolano de Investimentos (BAI), Banco Millennium Atlântico (BMA), Banco BIC, Standard Bank Angola (SBA), and Banco de Poupança e Crédito (BPC). Their additional capital buffers, known as a Systemic Risk Buffer, are set between 1.5% and 2% of their risk-weighted assets.
Conversely, five other banks previously classified as systemic—Banco Económico, Banco Sol, Banco Keve, BNI, and BCI—have been exempted from establishing these specific reserves. They must, however, maintain their existing capital requirements (around 1%) only until December 31, 2025, marking a transitional phase-out.
Understanding the “Too Big to Fail” Doctrine and Capital Buffers
The core rationale behind this policy is the global financial principle of “too big to fail.” This concept acknowledges that the collapse of a massively interconnected, complex, and large institution would cause catastrophic ripple effects across the entire economy, far beyond its shareholders and creditors. The 2008 global financial crisis was a stark lesson in this systemic risk.
The BNA’s required reserve is not a penalty but a pre-emptive capital cushion. Its purpose is threefold:
- Absorb Losses: To provide a higher-quality capital base that can absorb unexpected losses during a crisis without requiring a taxpayer-funded bailout.
- Reduce Risk-Taking: To incentivize more prudent management by making aggressive expansion and risky activities more capital-intensive.
- Protect the System: To limit the “domino effect” of contagion if one major bank becomes insolvent, thereby protecting depositors, other financial institutions, and the real economy.
The capital in question must be in the form of Common Equity Tier 1 (CET1), the highest quality regulatory capital. CET1 consists primarily of common shares and retained earnings—real, loss-absorbing equity that cannot vanish overnight. The BNA mandates this buffer can be up to 4% of risk-weighted assets, but the initial assignment for the six banks is between 1.5% and 2%.
The Tiered Approach: Why BAI and BFA Face the Highest Requirement
The BNA’s tiered application (2% for BAI and BFA, 1.5% for the others) reflects a nuanced risk assessment based on specific criteria:
- Size & Market Share: The collective dominance of these six banks is staggering. As of the first nine months of the year, they command 69% of total banking assets (25.6 trillion Kz), 70% of deposits, 71% of the credit stock, and a colossal 90% of the banking sector’s equity.
- Interconnectedness: Their deep links with other banks, businesses, and government entities mean trouble for one could quickly spread.
- Complexity & Substitutability: The complexity of their operations and the difficulty of replacing their essential services (like national payment systems) in a crisis.
BAI, as the leader in assets, loans, and profits, and BFA, as the clear number two, naturally attract the highest buffer requirement due to their outsized influence.
The Banco Económico Conundrum: A Case Study in De-risking
The exemption of Banco Económico is particularly telling and highlights the dynamic nature of systemic risk assessment. The bank has been in a state of technical bankruptcy and liquidity crisis for six years. Financial experts argue it no longer meets the core “systemic” criteria—not because it’s healthy, but because its market footprint and interconnectedness have likely shrunk to a point where its failure, while severe for its stakeholders, would not cripple the national system.
This illustrates a critical point: systemic importance is not a permanent label. The BNA’s move suggests it is actively differentiating between historically large banks and currently system-critical banks, allowing it to focus regulatory resources and requirements where the real, present-day risk lies. The resolution of Banco Económico’s long-standing issues is now framed as a contained problem rather than a systemic threat.
Strategic Implications and Forward Look
This policy shift by the BNA signals a maturation of Angola’s financial regulatory approach. It moves beyond a one-size-fits-all model to a targeted, risk-sensitive framework aligned with international best practices (like Basel III). For the six designated banks, it means holding more capital, which could marginally impact profitability and lending capacity but ultimately creates a more resilient institution. For the exempted banks, it removes a regulatory burden but also implicitly acknowledges their reduced systemic role.
The 2026 effective date provides a lengthy implementation window, allowing banks to adjust their capital planning organically. This measured timeline helps avoid sudden shocks to credit markets. Ultimately, this recalibration aims to create a more robust Angolan financial system—one where critical banks are stronger, and the state’s exposure to potential bailouts is minimized, fostering greater long-term economic stability and investor confidence.











