Argentina’s central bank moved Banco Comafi and Banco Industrial into its highest size category for 2026 without requiring either bank’s measurement to hold for a confirmation year. The two were in Group B in the BCRA’s 2025 list and appear in Group A in the 2026 list.
The label changed their constraints on two dates. Comafi and Industrial received Group A minimum-cash treatment on January 1. Their former 17% operational-risk capital ceiling stayed through June 30, then rose to 20% on July 1. One annual calculation can now move a bank into a costlier prudential tier.
One data year, no waiting year
Communication A 8364, issued on December 11, 2025, replaced Groups A, B and C with Groups A and B. Group A now captures institutions whose indicator is at least 1% of the financial system. The indicator adds average assets to average daily deposits over the 12 months from October of the second-preceding year through September of the preceding year. Group B holds every other institution.
The old rule used average assets for July through September and held smaller threshold movements for confirmation. A Group B bank measuring between 1% and 1.5% stayed in B for the next year. It moved to A only if the following calculation remained at or above 1%, unless it had crossed 1.5% immediately. The BCRA’s marked comparison shows those clauses removed.
A 12-month window reduces sensitivity to a brief balance-sheet jump. Deposits recognise that a large funding franchise matters even when assets sit below the old cutoff. Removing confirmation gives that broader measure an immediate consequence.
A longer measurement window reduces noise. Removing the waiting year increases speed.
The annual lists show the migration. Comafi and Industrial moved from B to A. All 44 former Group C entities moved to B. HSBC Bank Argentina appears in the 2025 list but not the 2026 list; the communications do not state why. Group A rose from 16 names to 17 despite adding two banks.
These were not marginal finance companies. In the BCRA’s January 2026 entity report, Banco Industrial ranked 14th by deposits with ARS2.610 trillion and Banco Comafi ranked 16th with ARS2.483 trillion. Their combined deposit base was just over ARS5.09 trillion.
The reserve schedule makes the label expensive
Group A status carries much higher reserve rates on common peso funding. Under the BCRA’s minimum-cash rules current on September 10, covered demand deposits face a 45% requirement for Group A banks and covered foreign G-SIB units, against 20% for other institutions. Peso term deposits of up to 29 days face 28.5% versus 14.5%. The gap narrows with maturity and disappears at 90 days.
For every ARS100 of covered peso demand funding, the headline gap is ARS25 of required reserves. For a term deposit due within 29 days, it is ARS14. Some requirements can be integrated with eligible government securities, so not every peso must sit idle as cash. Public rankings also omit the daily currency and maturity mix needed to calculate either bank’s exact incremental requirement.
The capital change is narrower but often misread. The percentage is not an overall capital ratio. It caps monthly operational-risk capital for non-systemic Group 2 institutions at a share of their inflation-adjusted average credit-risk capital minimum over the preceding 36 months.
The BCRA’s current capital rules stage the change. Comafi and Industrial kept the former Group B ceiling of 17% through June, even though their Group A reserve treatment began on January 1. The new Group A ceiling of 20% applied on July 1. That is a 3 percentage point increase in the reference base, or 17.6% relative to the former cap, before supervisory-rating reductions.
The 44 former Group C institutions kept a 14% standard ceiling through June, with reductions to 8% or 5% for qualifying scores. On July 1, the new Group B ceiling became 17%, with reductions to 11% or 7%. The actual charge remains the lower of the income-based calculation and the applicable ceiling.
Size and systemic importance split apart
The BCRA later separated size from systemic importance in liquidity regulation. Communication A 8445, dated June 4, limits the liquidity coverage ratio and net stable funding ratio to domestic systemically important banks and local branches or subsidiaries of foreign G-SIBs. Other Group A banks must keep reporting liquidity data but do not automatically fall inside both ratios merely because of the A label.
Institutions newly covered by that June measure must comply from October 1, 2026. Future changes in D-SIB or foreign G-SIB status receive three months to apply the treatment for their new systemic group. That is a separate transition rule. It does not restore the confirmation year abolished for the A and B size classification.
The result is a two-track regime. The annual A and B calculation drives reserve schedules, governance separation and an operational-risk capital ceiling. A narrower systemic classification drives the two Basel liquidity ratios.
Banks near the 1% boundary now need to prepare before the BCRA publishes the annual list. The 12-month window makes the signal easier to forecast. The absence of confirmation makes delay more costly. Banco Comafi and Banco Industrial show that the distinction is not theoretical: one December list changed the reserve economics of more than ARS5 trillion in deposits from January.
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