We propose a new backtesting framework for Expected Shortfall that could be
used by the regulator. Instead of looking at the estimated capital reserve and
the realised cash-flow separately, one could bind them into the secured
position, for which risk measurement is much easier. Using this simple concept
combined with monotonicity of Expected Shortfall with respect to its target
confidence level we introduce a natural and efficient backtesting framework.
Our test statistics is given by the biggest number of worst realisations for
the secured position that add up to a negative total. Surprisingly, this simple
quantity could be used to construct an efficient backtesting framework for
unconditional coverage of Expected Shortfall in a natural extension of the
regulatory traffic-light approach for Value-at-Risk. While being easy to
calculate, the test statistic is based on the underlying duality between
coherent risk measures and scale-invariant performance measures