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Blog · Coverage and territory · Compliance

Incident reporting against activity: the unit that reports nothing is not the safest one

How a compliance team reads its incident and near-miss reports against the activity that produces them, from the incident register and the activity data: reports per unit of activity, transactions, trades, accounts opened, the units well below the firm's own rate, the rate against the unit's audit findings, why a low reporting rate with high findings is a culture measure, and the list of units where the register is quiet and the evidence is not.

The short answerIncidents and near-misses are reported at a rate per unit of activity, and the firm's own rate across units is the norm. A unit reporting far below it is either safer or quieter, and its audit findings say which: a low reporting rate with findings at or above the norm is under-reporting, which is a culture measure. Per unit, reports per activity against the norm, beside findings per activity, put the quiet units on a list, and the compliance head's conversation is with the unit head about why the register does not hear from them.

A compliance head looks at the incident register and sees that one business unit has reported nothing this year. Either it is the safest unit in the firm or it is the quietest, and the audit findings say which. This guide sets out reporting rate against activity, the norm across units, the comparison to findings, and the quiet-unit list.

The measures

Per unit, per period:

Reporting rate = incidents and near-misses reported ÷ activity volume, per thousand Norm = the firm's median reporting rate across units Findings rate = audit and monitoring findings ÷ activity volume, per thousand Reports per finding = reporting rate ÷ findings rate

Quiet if reporting rate < a stated share of the norm and findings rate ≥ the norm.

The rows you need

  • Incident register: incident, unit, date, type, source: self-reported or found.
  • Activity data: unit, period, volume.
  • Findings: finding, unit, date, rating.

Unit identifiers only.

The assertion

incidents = self-reported + found by monitoring + found by audit

Every incident in one source. An incident with no source is listed; source is what separates reporting from finding.

A worked view

Unit Activity (thousands) Reports Reporting rate Norm Findings rate Reports per finding Reading
Payments 840 126 0.15 0.12 0.04 3.8 Reporting culture working
Lending 310 31 0.10 0.12 0.05 2.0 Normal
Treasury 120 2 0.02 0.12 0.06 0.3 Quiet, with findings above norm
Wealth 95 14 0.15 0.12 0.02 7.5 Working

Treasury reports one sixth of the firm's rate and has more findings per transaction than anyone. Two self-reports and seven findings: the register is not hearing what the auditors are.

The conversation

With the unit head, about the register: whether staff know what to report, whether reporting is safe, whether anyone reads it. Not about the two incidents. The reports-per-finding ratio is the number on the table, and it is a culture number.

Trend

Unit Reports per finding, 4 quarters ago Now
Treasury 1.1 0.3

The register went quiet over a year. Something changed in the unit, and the date narrows it.

Where it goes wrong

Raw report counts. The big unit reports most; the small one looks fine.

Low reporting read as safe. The quiet unit praised.

Findings not beside reports. No independent check.

No trend. A register that went quiet reads as one that was always quiet.

Every quarter, reporting against activity and findings

Mapped once, the incident register, the activity data and the findings produce the rates, the norm, reports per finding and the quiet-unit list every quarter. Covirage builds this from the exports as they are. The compliance page describes the setup, and the issue ageing guide covers what happens to the findings the quiet unit did not report first.

Questions people ask

What is the activity denominator?

The volume the unit does that could produce an incident: transactions, trades, accounts opened, payments processed, from the unit's own activity data. Reports per thousand transactions is comparable across units of different size in a way that raw counts are not.

Why compare to audit findings?

Because findings are the independent record of what went wrong, and a unit whose findings are normal and whose self-reports are near zero is not reporting what it finds. The ratio of reports to findings per unit is the honest signal, and it is the one a regulator reads the same way.

Is a high reporting rate good?

Usually. A unit that reports many near-misses and has few findings is one where the register is used as intended. The report shows both, so the high reporter is read as the culture the firm wants, not as the problem unit.