Commonwealth Bank of Australia is committed to addressing issues raised by the Australian Prudential Regulation Authority's inquiry into its governance, culture and accountability but the bank's sheer size and the complexity of its remedial action plan are likely to pose ongoing execution challenges, according to a report from the firm reviewing the plan.

In its first quarterly report, Promontory Australasia observed that the bank's design and management of the plan "evidences a commitment to meeting the challenges described in the inquiry report in a timely and comprehensive way." The firm, however, noted that the plan's implementation could be a long and complex process given CBA's size and the breadth of its activities.

"Moving forward, the sheer size of CBA, the extent to which existing processes and sub-culture are embedded, and the complexity of the program are likely to pose ongoing execution challenges," the firm said.

Promontory Australasia was engaged as the independent reviewer of CBA's remedial action plan to address the recommendations of APRA's prudential inquiry into the bank. APRA's inquiry report in May had identified a series of shortcomings at CBA and made 35 recommendations to address the issues. CBA was also asked to develop a plan to address the issues.

CBA has also established a board and executive committee oversight and "appears to be responding to delivery risks in a timely way," Promontory Australasia said. Further, the bank has tied the performance metrics of its senior leaders to the successful delivery of the remedial action plan.

Promontory Australasia will release its next report in December.