“The Notes constitute direct, general, unconditional and unsubordinated obligations of the Issuer”Condition 3 (Status), p.30
IAN SPPI Lens — worked examples
9 instruments, assessed end to end against 65IFRS 9 tests — 3 that pass and 6 that do not. Every verdict carries the sentence it relied on, the page that sentence sits on, and the rule applied.
ACME Industries 4.00% Senior Notes due 2032
A plain senior unsecured fixed-rate bullet bond. The reference case: fixed coupon, par redemption, one currency, no options. It passes all 65.
PASS — The instrument's contractual cash flows are solely payments of principal and interest on the principal amount outstanding (SPPI met).
| Category | Pass | Further enquiry | Fail | Category verdict | Failing tests |
|---|---|---|---|---|---|
| A Instrument Identity & Legal Form | 6 | 0 | 0 | Pass | — |
| B Time Value of Money | 8 | 0 | 0 | Pass | — |
| C Credit Risk Compensation | 6 | 0 | 0 | Pass | — |
| D Leverage & Non-Basic Lending | 7 | 0 | 0 | Pass | — |
| E Contingent & Event-Driven | 10 | 0 | 0 | Pass | — |
| F Prepayment & Extension | 8 | 0 | 0 | Pass | — |
| G Currency & Indexation | 6 | 0 | 0 | Pass | — |
| H Structural & Residual Risk | 14 | 0 | 0 | Pass | — |
The evidence behind the verdicts
This instrument passes all 65 tests. Three of them are shown with the exact terms relied on.
“each Note will be redeemed at its principal amount (100 per cent. of nominal) on the Maturity Date”Condition 6.1 (Redemption), p.42
“the Notes bear interest at the rate of 4.00 per cent. per annum”Condition 4 (Interest), p.36
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ACME Utilities 1.25% RPI-Linked Senior Notes due 2040
The one that surprises people. A simple, unleveraged link to a published inflation index is consistent with basic lending — it preserves real purchasing power rather than adding exposure to something other than credit and time value.
PASS — The instrument's contractual cash flows are solely payments of principal and interest on the principal amount outstanding (SPPI met).
| Category | Pass | Further enquiry | Fail | Category verdict | Failing tests |
|---|---|---|---|---|---|
| A Instrument Identity & Legal Form | 6 | 0 | 0 | Pass | — |
| B Time Value of Money | 8 | 0 | 0 | Pass | — |
| C Credit Risk Compensation | 6 | 0 | 0 | Pass | — |
| D Leverage & Non-Basic Lending | 7 | 0 | 0 | Pass | — |
| E Contingent & Event-Driven | 10 | 0 | 0 | Pass | — |
| F Prepayment & Extension | 8 | 0 | 0 | Pass | — |
| G Currency & Indexation | 6 | 0 | 0 | Pass | — |
| H Structural & Residual Risk | 14 | 0 | 0 | Pass | — |
The evidence behind the verdicts
This instrument passes all 65 tests. Three of them are shown with the exact terms relied on.
“Unleveraged: no gearing to the inflation outcome.”Condition 5.2 (Index Ratio), p.51
“the Index means the UK Retail Prices Index (RPI) published monthly by the Office for National Statistics”Condition 5.1 (Definitions), p.50
“Standard three-month lag; no complex or compounding adjustment.”Condition 5.2 (Index Ratio), p.51
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ACME Industries USD 3.50% Senior Notes due 2030
Denominated in a currency that is not the issuer's functional currency. Denomination alone is not an SPPI problem; a dual-currency or FX-linked payout would be.
PASS — The instrument's contractual cash flows are solely payments of principal and interest on the principal amount outstanding (SPPI met).
| Category | Pass | Further enquiry | Fail | Category verdict | Failing tests |
|---|---|---|---|---|---|
| A Instrument Identity & Legal Form | 6 | 0 | 0 | Pass | — |
| B Time Value of Money | 8 | 0 | 0 | Pass | — |
| C Credit Risk Compensation | 6 | 0 | 0 | Pass | — |
| D Leverage & Non-Basic Lending | 7 | 0 | 0 | Pass | — |
| E Contingent & Event-Driven | 10 | 0 | 0 | Pass | — |
| F Prepayment & Extension | 8 | 0 | 0 | Pass | — |
| G Currency & Indexation | 6 | 0 | 0 | Pass | — |
| H Structural & Residual Risk | 14 | 0 | 0 | Pass | — |
The evidence behind the verdicts
This instrument passes all 65 tests. Three of them are shown with the exact terms relied on.
“Simple single (foreign) currency denomination — permitted; no FX-linked adjustment.”Condition 7 (Payments), p.45
“The Notes constitute direct, general, unconditional and unsubordinated obligations of the Issuer”Condition 3 (Status), p.30
“each Note will be redeemed at its principal amount (100 per cent. of nominal) on the Maturity Date”Condition 6.1 (Redemption), p.42
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ACME Industries 4.25% Sustainability-Linked Notes due 2031
A coupon step-up tied to a sustainability performance target. Fails because the adjustment is not compensation for credit risk or the time value of money.
FAIL — The instrument does NOT meet SPPI. Disqualifying feature(s) evidenced at: E8.
| Category | Pass | Further enquiry | Fail | Category verdict | Failing tests |
|---|---|---|---|---|---|
| A Instrument Identity & Legal Form | 6 | 0 | 0 | Pass | — |
| B Time Value of Money | 8 | 0 | 0 | Pass | — |
| C Credit Risk Compensation | 6 | 0 | 0 | Pass | — |
| D Leverage & Non-Basic Lending | 7 | 0 | 0 | Pass | — |
| E Contingent & Event-Driven | 9 | 0 | 1 | Fail | E8 |
| F Prepayment & Extension | 8 | 0 | 0 | Pass | — |
| G Currency & Indexation | 6 | 0 | 0 | Pass | — |
| H Structural & Residual Risk | 13 | 0 | 1 | Fail | H14 |
The evidence behind the verdicts
Every failing test, with the sentence from the offering document that produced it — then three passing tests, so you can see what a pass looks like when it is evidenced rather than assumed.
“a one-way 75bps step-up applies only on failure and is not symmetric (no step-down)”Condition 4.3 (Sustainability Step-up), p.39
“The Notes constitute direct, general, unconditional and unsubordinated obligations of the Issuer”Condition 3 (Status), p.30
“each Note will be redeemed at its principal amount (100 per cent. of nominal) on the Maturity Date”Condition 6.1 (Redemption), p.42
“the Notes bear interest at the rate of 4.00 per cent. per annum”Condition 4 (Interest), p.36
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Example Residential Mortgage Securities 2026-1 Class A Notes
A senior residential mortgage tranche. Even the AAA class fails: the cash flows depend on a pool, losses are allocated by seniority, and a waterfall decides who is paid.
FAIL — The instrument does NOT meet SPPI. Disqualifying feature(s) evidenced at: H4, H5, H6, H8.
| Category | Pass | Further enquiry | Fail | Category verdict | Failing tests |
|---|---|---|---|---|---|
| A Instrument Identity & Legal Form | 6 | 0 | 0 | Pass | — |
| B Time Value of Money | 8 | 0 | 0 | Pass | — |
| C Credit Risk Compensation | 6 | 0 | 0 | Pass | — |
| D Leverage & Non-Basic Lending | 7 | 0 | 0 | Pass | — |
| E Contingent & Event-Driven | 10 | 0 | 0 | Pass | — |
| F Prepayment & Extension | 8 | 0 | 0 | Pass | — |
| G Currency & Indexation | 6 | 0 | 0 | Pass | — |
| H Structural & Residual Risk | 9 | 0 | 5 | Fail | H4, H5, H6, H8, H14 |
The evidence behind the verdicts
Every failing test, with the sentence from the offering document that produced it — then three passing tests, so you can see what a pass looks like when it is evidenced rather than assumed.
“Available Revenue Receipts shall be applied on each Interest Payment Date in accordance with the Pre-Enforcement Revenue Priority of Payments”Cashflows / Priority of Payments, p.98
“the Notes are issued in Classes A, B, C, D and E; principal losses on the Mortgage Pool are borne by the Classes in reverse alphabetical order”Loss Allocation, p.104
“payments on the Notes are funded solely by collections on the Mortgage Pool and the Issuer has no other assets or recourse”The Mortgage Pool, p.61
“following a breach of the Arrears Trigger, all Available Principal Receipts shall be applied sequentially rather than pro rata”Trigger Events, p.101
“The Notes constitute direct, general, unconditional and unsubordinated obligations of the Issuer”Condition 3 (Status), p.30
“each Note will be redeemed at its principal amount (100 per cent. of nominal) on the Maturity Date”Condition 6.1 (Redemption), p.42
“the Notes bear interest at the rate of 4.00 per cent. per annum”Condition 4 (Interest), p.36
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Example CLO 2026-1 Class A-1 Senior Secured Notes
A AAA CLO senior tranche. Worth reading beside the RMBS: the two fail on overlapping but distinguishable grounds, which shows what the rules are actually keying on.
FAIL — The instrument does NOT meet SPPI. Disqualifying feature(s) evidenced at: H4, H5, H6, H8.
| Category | Pass | Further enquiry | Fail | Category verdict | Failing tests |
|---|---|---|---|---|---|
| A Instrument Identity & Legal Form | 6 | 0 | 0 | Pass | — |
| B Time Value of Money | 8 | 0 | 0 | Pass | — |
| C Credit Risk Compensation | 6 | 0 | 0 | Pass | — |
| D Leverage & Non-Basic Lending | 7 | 0 | 0 | Pass | — |
| E Contingent & Event-Driven | 10 | 0 | 0 | Pass | — |
| F Prepayment & Extension | 8 | 0 | 0 | Pass | — |
| G Currency & Indexation | 6 | 0 | 0 | Pass | — |
| H Structural & Residual Risk | 9 | 0 | 5 | Fail | H4, H5, H6, H8, H14 |
The evidence behind the verdicts
Every failing test, with the sentence from the offering document that produced it — then three passing tests, so you can see what a pass looks like when it is evidenced rather than assumed.
“amounts available for distribution shall be applied in accordance with the Priority of Payments (the 'Waterfall')”Condition 3 / Priority of Payments, p.90
“the Notes are issued in a series of Classes ranked by seniority; losses on the Portfolio are allocated to Classes in reverse order of seniority”Priority of Payments / Loss Allocation, p.88
“payments on the Notes depend on collections received on a diversified portfolio of senior secured loans”Collateral / Portfolio, p.72
“diversion of cash flows on breach of Overcollateralisation and Interest Coverage Tests”Coverage Tests, p.95
“The Notes constitute direct, general, unconditional and unsubordinated obligations of the Issuer”Condition 3 (Status), p.30
“each Note will be redeemed at its principal amount (100 per cent. of nominal) on the Maturity Date”Condition 6.1 (Redemption), p.42
“the Notes bear interest at the rate of 4.00 per cent. per annum”Condition 4 (Interest), p.36
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Example Bank 7.5% Perpetual Additional Tier 1 Capital Notes
Additional Tier 1. The heaviest failure in the set — discretionary coupons, a regulatory trigger, contingent conversion and no maturity date.
FAIL — The instrument does NOT meet SPPI. Disqualifying feature(s) evidenced at: A2, C4, C5, C6, E1, E2, E3, E4, F8, H1, H9.
| Category | Pass | Further enquiry | Fail | Category verdict | Failing tests |
|---|---|---|---|---|---|
| A Instrument Identity & Legal Form | 4 | 1 | 1 | Fail | A2 |
| B Time Value of Money | 8 | 0 | 0 | Pass | — |
| C Credit Risk Compensation | 3 | 0 | 3 | Fail | C4, C5, C6 |
| D Leverage & Non-Basic Lending | 7 | 0 | 0 | Pass | — |
| E Contingent & Event-Driven | 6 | 0 | 4 | Fail | E1, E2, E3, E4 |
| F Prepayment & Extension | 7 | 0 | 1 | Fail | F8 |
| G Currency & Indexation | 6 | 0 | 0 | Pass | — |
| H Structural & Residual Risk | 11 | 0 | 3 | Fail | H1, H9, H14 |
The evidence behind the verdicts
Every failing test, with the sentence from the offering document that produced it — then three passing tests, so you can see what a pass looks like when it is evidenced rather than assumed.
“the Notes are stated to be subordinated capital instruments”Condition 3 (Status), p.32
“the Issuer may elect, in its sole and absolute discretion, to cancel any interest payment, in whole or in part; cancelled interest shall not accumulate or become payable”Condition 5 (Interest Cancellation), p.40
“the Notes are designed to absorb losses on a going-concern basis”Overview / Risk Factors, p.18
“the Notes are deeply subordinated and rank junior to all other creditors, with going-concern loss absorption”Condition 3 (Status), p.32
“the Notes convert into ordinary shares upon a Trigger Event”Condition 6 (Conversion), p.52
“the Issuer may elect, in its sole and absolute discretion, to cancel any interest payment, in whole or in part; cancelled interest shall not accumulate or become payable”Condition 5 (Interest Cancellation), p.40
“alternatively the principal amount may be written down (in whole or in part) upon a Trigger Event”Condition 6 (Write-down), p.53
“upon the occurrence of a Trigger Event (CET1 ratio below 7.0%) the Notes shall convert into ordinary shares of the Issuer”Condition 6 (Conversion), p.52
“a Trigger Event occurs if the Group's Common Equity Tier 1 ratio falls below 7.0%, or upon a Point of Non-Viability determination”Condition 6 (Trigger Event), p.52
“redeemable at the Issuer's option (subject to regulatory consent) but with no obligation ever to redeem”Condition 6 (Issuer Call), p.51
“Perpetual — no contractual maturity at which principal is due.”Condition 6 (Redemption), p.50
“the Notes are subject to the exercise of the UK Bail-in Power by the relevant Resolution Authority”Condition 20 (Bail-in), p.70
“each Note will be redeemed at its principal amount (100 per cent. of nominal) on the Maturity Date”Condition 6.1 (Redemption), p.42
“the Notes bear interest at the rate of 4.00 per cent. per annum”Condition 4 (Interest), p.36
“the rate was set by reference to the Issuer's credit standing and prevailing market rates at issue”Condition 4 (Interest), p.36
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Example SPV Leveraged Inverse Floating Rate Notes due 2031
A leveraged inverse floater. Interest moves the wrong way and is geared, so it is not compensation for the passage of time.
FAIL — The instrument does NOT meet SPPI. Disqualifying feature(s) evidenced at: B3, B4, B7, D1.
| Category | Pass | Further enquiry | Fail | Category verdict | Failing tests |
|---|---|---|---|---|---|
| A Instrument Identity & Legal Form | 6 | 0 | 0 | Pass | — |
| B Time Value of Money | 5 | 0 | 3 | Fail | B3, B4, B7 |
| C Credit Risk Compensation | 6 | 0 | 0 | Pass | — |
| D Leverage & Non-Basic Lending | 6 | 0 | 1 | Fail | D1 |
| E Contingent & Event-Driven | 10 | 0 | 0 | Pass | — |
| F Prepayment & Extension | 8 | 0 | 0 | Pass | — |
| G Currency & Indexation | 6 | 0 | 0 | Pass | — |
| H Structural & Residual Risk | 13 | 0 | 1 | Fail | H14 |
The evidence behind the verdicts
Every failing test, with the sentence from the offering document that produced it — then three passing tests, so you can see what a pass looks like when it is evidenced rather than assumed.
“the reference rate is multiplied by a factor of two (2 x 3-month EURIBOR)”Condition 4 (Interest), p.38
“interest = 9.00% minus 2 x 3-month EURIBOR, subject to a floor of zero”Condition 4 (Interest), p.38
“the inverse formula with a zero floor produces an asymmetric, non-linear payoff”Condition 4 (Interest), p.38
“the 2x multiplier magnifies sensitivity to changes in EURIBOR”Condition 4 (Interest), p.38
“The Notes constitute direct, general, unconditional and unsubordinated obligations of the Issuer”Condition 3 (Status), p.30
“each Note will be redeemed at its principal amount (100 per cent. of nominal) on the Maturity Date”Condition 6.1 (Redemption), p.42
“the Notes bear interest at the rate of 4.00 per cent. per annum”Condition 4 (Interest), p.36
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Example Re Ltd Series 2026-1 Class A Principal-at-Risk Variable Rate Notes
The one that fails on the weather. Principal is written down when a named storm crosses a stated pressure or an earthquake exceeds a stated magnitude — a trigger that can fire while the issuer is perfectly solvent, and that says nothing about whether it can pay.
FAIL — The instrument does NOT meet SPPI. Disqualifying feature(s) evidenced at: C1, C4, E2, E6.
| Category | Pass | Further enquiry | Fail | Category verdict | Failing tests |
|---|---|---|---|---|---|
| A Instrument Identity & Legal Form | 6 | 0 | 0 | Pass | — |
| B Time Value of Money | 8 | 0 | 0 | Pass | — |
| C Credit Risk Compensation | 4 | 0 | 2 | Fail | C1, C4 |
| D Leverage & Non-Basic Lending | 7 | 0 | 0 | Pass | — |
| E Contingent & Event-Driven | 8 | 0 | 2 | Fail | E2, E6 |
| F Prepayment & Extension | 8 | 0 | 0 | Pass | — |
| G Currency & Indexation | 6 | 0 | 0 | Pass | — |
| H Structural & Residual Risk | 13 | 0 | 1 | Fail | H14 |
The evidence behind the verdicts
Every failing test, with the sentence from the offering document that produced it — then three passing tests, so you can see what a pass looks like when it is evidenced rather than assumed.
“The margin is an insurance risk premium priced off catastrophe modelling — it does not compensate the borrower's own credit risk.”Condition 4.2 (Risk Spread) and Risk Analysis, p.37
“Noteholders bear the Event Payment in full; a reduction of the Outstanding Principal Amount does not constitute an Event of Default and may occur while the Issuer and the Ceding Insurer remain fully solvent and current on all obligations”Condition 7.4 and Risk Factors, p.20
“on each Event Payment Date the Outstanding Principal Amount shall be reduced by the Event Payment Amount calculated under the Payout Factor table, and such reduction shall be permanent and shall not be reinstated”Condition 7.3 (Principal Reduction), p.61
“an Event Payment shall become due if, during the Risk Period, a Named Storm makes landfall within the Covered Area with a Minimum Central Pressure at or below 950 millibars, or an Earthquake of Moment Magnitude 7.0 or greater occurs within the Covered Area, in each case as reported by the Reporting Agency”Condition 7.1 (Event Payment) and Annex A (Parametric Trigger), p.60
“interest on each Payment Date comprises the Collateral Return on the Permitted Investments plus the Risk Spread”Condition 4.1 (Interest), p.36
“The Notes constitute direct, general, unconditional and unsubordinated obligations of the Issuer”Condition 3 (Status), p.30
“each Note will be redeemed at its principal amount (100 per cent. of nominal) on the Maturity Date”Condition 6.1 (Redemption), p.42
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Your own documents
Open SPPI Lens to attach your own offering documents. Each is assessed on its own and returns its own report.
This is a screening aid, not a determination
- It is an opinion. This report is a screening aid. It is not accounting, audit, legal, tax or investment advice, and it is not a determination of anything.
- It covers one document, and we did not choose it. The assessment is based solely on the document you supplied. That document has not been independently verified as the governing offering document for the instrument named. If the wrong document was uploaded, the verdicts describe the wrong instrument.
- The classification is yours. IFRS 9 classification is the responsibility of the reporting entity and its auditors. Verify every result independently before relying on it for any financial reporting, valuation or investment decision.
- The engine can misread a document. A verdict of further enquiry means the document was silent or ambiguous on that point, not that the instrument fails. Treat every verdict as a prompt to read the clause quoted beside it.
- No liability, and no professional relationship. Insurance Asset News accepts no liability for any decision taken in reliance on this output. Using this tool creates no professional relationship and is not a substitute for professional advice.
Draft wording, pending legal review. It will be replaced once a solicitor has settled it. (v2026-08-draft-1)








