At a Glance
The NCUA’s 2026 Supervisory Priorities reaffirm the agency’s commitment to risk-based supervision while highlighting key areas of examination focus for the year ahead. Credit unions can expect continued attention to balance sheet management, credit risk, interest rate and liquidity risk, and operational resilience, alongside ongoing expectations for strong compliance and governance practices. Across all areas, the priorities emphasize clear documentation, active board oversight, and proactive risk management as essential components of examination readiness and long-term institutional stability.
Contents
- Continued Emphasis on Risk-Based Supervision
- Heightened Focus on Balance Sheet and Credit Risk Management
- Interest Rate and Liquidity Risk Remain in Focus
- Operational Resilience and Compliance Expectations
- Efficiency, Innovation, and Supervisory Modernization
- Governance and Documentation as Cross-Cutting Themes
- Looking Ahead
Continued Emphasis on Risk-Based Supervision
At the foundation of the NCUA’s 2026 Supervisory Priorities is its continued commitment to risk-based supervision. Rather than applying uniform examination procedures across all institutions, examiners will tailor their scope and depth based on each credit union’s size, complexity, and unique risk profile.
This approach is intended to focus supervisory attention on areas that present the greatest potential risk to members, the institution, and the National Credit Union Share Insurance Fund. For executive teams and boards, it reinforces the importance of clearly understanding their risk exposure and ensuring that internal controls and oversight align with that profile.
Heightened Focus on Balance Sheet and Credit Risk Management
Balance sheet strength and credit risk management stand out as key areas of emphasis for 2026. With changing economic conditions affecting borrower performance, the NCUA has signaled increased attention to how credit unions manage lending risk across their portfolios.
Examiners are expected to focus on institution-specific risks and may include reviewing underwriting practices, portfolio credit risk concentrations, monitoring and reporting processes, and how institutions respond to early warning signs of credit deterioration. Allowance for credit losses methodologies and supporting documentation will also receive scrutiny, particularly as loan performance trends evolve.
Credit unions should be prepared to demonstrate that credit risk management is proactive, data-driven, and integrated into broader strategic decision-making.
Interest Rate and Liquidity Risk Remain in Focus
The ongoing impact of a higher interest rate environment continues to shape supervisory expectations. Interest rate risk and liquidity risk remain central examination themes as credit unions navigate balance sheet repricing, funding costs, and member behavior.
Examiners will assess how institutions measure and manage sensitivity to interest rate changes, evaluate liquidity under stressed conditions, and incorporate these risks into capital and strategic planning. Clear assumptions, robust modeling, and documented management and board oversight will be critical in demonstrating sound risk management practices.
Operational Resilience and Compliance Expectations
Operational risk continues to be a significant area of supervisory focus in 2026. The NCUA’s priorities highlight examiner attention on payment systems, fraud prevention, and the reliability of operational controls that support member services. Third-party risk management is another area of interest, particularly where vendors play a critical role in core operations or member-facing activities.
Compliance expectations also remain front and center. Examiners will evaluate how effectively credit unions comply with consumer protection requirements and maintain Bank Secrecy Act and anti-money laundering programs that are appropriately scaled to their operations. Significant developments and changes in the regulatory system are expected in 2026. Credit unions should stay informed to ensure their BSA policies, procedures, internal controls and overall AML programs remain in compliance.
Efficiency, Innovation, and Supervisory Modernization
Alongside its risk priorities, the NCUA continues to emphasize efficiency and modernization in its supervisory processes. The agency has indicated an ongoing effort to refine examination procedures, leverage data more effectively, and implement legislative changes that influence supervisory expectations.
For credit unions, this focus highlights the importance of strong documentation, consistent processes, and systems that support transparency and timely information sharing during examinations.
Governance and Documentation as Cross-Cutting Themes
Across all supervisory areas, strong governance and effective documentation remain consistent expectations. Boards and senior management are expected to play an active role in setting risk appetite, overseeing key risk areas, and ensuring policies are not only well designed but actively implemented and reviewed.
Institutions that demonstrate clear accountability, regular board engagement, and forward-looking risk management practices will be better positioned to navigate examinations and respond to supervisory feedback.
Looking Ahead
The NCUA’s 2026 Supervisory Priorities provide credit union leaders with a clear view of examination focus areas and regulatory expectations for the year ahead. While safety, soundness, and compliance remain central, the broader message emphasizes clarity, predictability, and collaboration. As credit unions prepare for upcoming examinations and strategic planning cycles, working with a qualified financial advisor can help leadership teams assess risk management practices, evaluate balance sheet strategies, strengthen governance, and align internal processes with supervisory expectations. Proactive guidance and independent perspective can be valuable tools in not only preparing for examinations, but also positioning the institution for long-term resilience and sustainable growth.
Nicole Davis is an Audit Manager with ARB who takes a proactive, solutions-driven approach to helping clients navigate complex financial and regulatory challenges. She specializes in providing audit, review, compilation, and agreed-upon procedures services to financial institutions, construction companies, manufacturers, and nonprofit organizations.
