The capital framework as implemented in the EU through CRR3 (Reg. (EU) 2024/1623, applying since 1 Jan 2025) and CRD6 (Dir. (EU) 2024/1619). Each block shows its parameters and the numbered steps by which the requirement is determined; grey boxes carry worked micro-examples. Market risk (FRTB) shown as applying from 1 Jan 2027 2027; transitional calibrations marked TRANS; Pillar 2 material marked PILLAR 2 — NOT IN TREA. Sections marked DETAIL ⧉ open a drawer with purpose, history, minimum requirements and worked examples; printed copies append that detail as booklet pages.
| CET1 | Additional Tier 1 | Tier 2 | |
|---|---|---|---|
| Maturity | Perpetual; no incentive to redeem | Perpetual; call ≥ 5y, supervisory approval, no expectation of call | Original maturity ≥ 5y; straight-line amortisation in the final 5y |
| Distributions | Fully discretionary, non-cumulative | Fully discretionary, non-cumulative; no dividend pushers/stoppers | Coupons payable; deferral not required |
| Loss absorption | First loss, going concern | Write-down / conversion at CET1 < 5.125% (or higher contractual trigger) | Gone concern — bail-in / insolvency |
| Subordination | Most junior claim | Senior only to CET1 | Senior to AT1; junior to all other liabilities |
Repurchase/reduction of any tier requires prior supervisory permission (Art 77–78); grandfathering of legacy instruments has lapsed.
Reading the bridge: Pillar 1 capital protects a going concern; MREL/TLAC ensures that, in resolution, the same balance sheet holds enough bail-in-able claims to absorb losses and rebuild the capital stack without public money. Cross-holdings of other G-SIIs' TLAC are deducted from own funds to stop contagion loops.
| Single client / group of connected clients | 25% Tier 1 |
| G-SII exposure to another G-SII | 15% Tier 1 |
| Large-exposure definition & reporting threshold | ≥ 10% Tier 1 |
| Discretion | Floor-only calibration |
|---|---|
| Low-risk residential mortgages (NL a.o., strict loss criteria) | 10% ≤ 55% of value · 45% remainder |
| Unrated corporates, own-estimate PD ≤ 0.5% | 65% RW |
| SEC-SA in the floor | p halved → 0.5 · STS 0.25 |
Cliff: all three lapse end-2032 unless extended by legislation — a low-risk mortgage book's S-TREA roughly doubles overnight in 2033.
| Unconditionally cancellable commitments | 10% PHASED · Art 495d |
| Other commitments (any maturity) | 40% |
| Transaction-related contingents · NIFs/RUFs | 50% |
| Short-term self-liquidating trade LCs | 20% |
| Direct credit substitutes, guarantees | 100% |
| Supervisory factor | SF |
|---|---|
| Interest rate | 0.5% |
| FX | 4.0% |
| Credit (single-name, by rating) | 0.38–6.0% |
| Equity — single / index | 32% / 20% |
| Commodity — other / electricity | 18% / 40% |
Worked examples → section detail ⧉.
| Method (eligibility by derivative business) | Calculation |
|---|---|
| SA-CCR — default | Full mechanics above: deltas, hedging sets, margin recognition, multiplier |
| Simplified SA-CCR — ≤ 10% of assets & ≤ €300m | same formula · mult = 1 · coarse add-ons, no supervisory deltas or margin refinement |
| Original exposure method (OEM) — ≤ 5% & ≤ €100m | EAD = 1.4 × (max(V,0) + N × supervisory % by asset class & maturity) |
| IMM — internal model, approval | EAD = α × effective EPE (expected positive exposure) · SA-CCR shadow still required for S-TREA |
| Supervisory haircuts HC | |
|---|---|
| Debt collateral (by issuer / maturity / CQS) | 0.5–15% |
| Main-index equities · gold | 20% |
| Other listed equities | 30% |
| Currency mismatch HFX | 8% |
| Collateral | Financial | Receivables | Resi / comm. RE | Other physical |
|---|---|---|---|---|
| LGD* | 0% | 10% | 10% | 15% |
| CQS → | 1 | 2 | 3 | 4 | 5 | 6 | Unrated |
|---|---|---|---|---|---|---|---|
| Sovereigns | 0% | 20% | 50% | 100% | 100% | 150% | 100%¹ |
| Institutions | 20% | 30% | 50% | 100% | 100% | 150% | SCRA ↓ |
| — short-term ≤ 3m | 20% | 20% | 20% | 50% | 50% | 150% | — |
| Corporates | 20% | 50% | 75% | 100% | 150% | 150% | 100%² |
| Covered bonds | 10% | 20% | 20% | 50% | 50% | 100% | derived |
| Grade | A+ / A | B | C |
|---|---|---|---|
| Base RW | 30% / 40% | 75% | 150% |
| Short-term ≤ 3m | 20% | 50% | 150% |
| Regulatory retail (granular, ≤ €1m) | 75% |
| — transactors (cards/charge, fully repaid) | 45% |
| Specialised lending — project (pre-op / op / high-quality) | 130% / 100% / 80% |
| — object & commodities finance | 100% |
| Subordinated debt / TLAC-eligible | 150% |
| Equity — standard / speculative unlisted TO 2030 | 250% / 400% |
| — long-term strategic (discretion) | 100% |
| Defaulted (unsecured, provisions < 20% / else) | 150% / 100% |
| Residential, general — loan-splitting | 20% ≤ 55% of value · rest cpty RW |
| Residential IPRE — whole loan, ETV ≤50/60/80/90/100/>100 | 30% · 35% · 45% · 60% · 75% · 105% |
| Commercial, general — split ≤ 55% of value | min(60%, cpty) · rest cpty |
| Commercial IPRE — ETV ≤60/80/>80 | 70% · 90% · 110% |
| ADC | 150% · 100% pre-sold resi |
Worked examples → section detail ⧉.
| Class | A-IRB | F-IRB | SA |
|---|---|---|---|
| Large corporates (rev > €500m) | ✕ | ✓ | ✓ |
| Other corporates | ✓ | ✓ | ✓ |
| Institutions & other financials | ✕ | ✓ | ✓ |
| Retail (mortgages, QRRE, other) | ✓ | n/a¹ | ✓ |
| Equity | ✕ | ✕ | ✓ only |
| PD — corporate & retail | 0.05% · QRRE revolver 0.10% |
| LGD unsecured — corporate / other retail / QRRE | 25% / 30% / 50% |
| LGD — residential mortgages | 5% |
| LGD secured — fin / receivables / RE / other phys. | 0% / 10% / 10% / 15% |
| EAD | ≥ on-bal + 50% × SA-CCF off-bal |
| Corporates | 0.12–0.24 by PD |
| — SME size adjustment (S = revenue €5–50m) | − 0.04·(1−(S−5)/45) |
| — large (≥ €100bn assets) / unregulated financials | × 1.25 |
| Residential mortgages / QRRE / other retail | 0.15 / 0.04 / 0.03–0.16 |
| Category | Strong | Good | Satisf. | Weak | Default |
|---|---|---|---|---|---|
| RW (M ≥ 2.5y) | 70% | 90% | 115% | 250% | 0%* |
| RW (M < 2.5y) | 50% | 70% | 115% | 250% | 0%* |
Worked examples → section detail ⧉.
Also in Part 3, small but mandatory: settlement/delivery risk charges for unsettled transactions and free deliveries (Art 378–380).
| Adjustment | Factor |
|---|---|
| SME supporting factor (turnover ≤ €50m) — part ≤ €2.5m / above | × 0.7619 / × 0.85 |
| Infrastructure supporting factor (qualifying projects) | × 0.75 |
| Unhedged retail FX lending — currency ≠ income currency | × 1.5 · RW cap 150% |
| Clearing member → QCCP | 2% |
| Client via member (conditions met / partial) | 2% / 4% |
| Non-QCCP | bilateral SA |
Worked examples → section detail ⧉.
| Test (trading + FX/commodity business) | Outcome |
|---|---|
| ≤ 5% of assets & ≤ €50m (Art 94) | banking-book treatment |
| ≤ 10% of assets & ≤ €500m (Art 325a) | Simplified SA eligible |
| Above · dealer profile | A-SA default · A-IMA per desk (approval) |
| Class | IR | EQ | FX | COM |
|---|---|---|---|---|
| Scalar | × 1.3 | × 3.5 | × 1.2 | × 1.9 |
Worked examples → section detail ⧉.
EU status: CRR2 market risk applies for own funds until 01·01·2027 (FRTB reporting continues). EBA no-action: boundary/IRT not supervisory priorities before then. 3rd Delegated Act (in scrutiny): optional overall multiplier (Art 495v) toward CRR2-IMA levels for adversely affected banks + operational relief, 2027–29.
| AAA | AA | A | BBB | BB | B | CCC | NR | Dflt |
|---|---|---|---|---|---|---|---|---|
| 0.5% | 2% | 3% | 6% | 15% | 30% | 50% | 15% | 100% |
| Backtesting (desk & top-of-house) | 97.5% & 99% VaR exceptions · traffic-light multiplier |
| P&L attribution (RTPL vs HPL) | Spearman + KS · green / amber (surcharge) / red (→ A-SA) |
| LH (days) | 10 | 20 | 40 | 60 | 120 |
|---|---|---|---|---|---|
| e.g. | IR/FX major, lg-cap eq | other IR/eq, energy | IG spread | HY spread, sm eq vol | structural/other |
Worked examples → section detail ⧉.
| Approach | Condition |
|---|---|
| Simplified: CVA OF = CCR OF | OEM-eligible (≤ 5% / €100m) |
| BA-CVA — reduced or full | default |
| SA-CVA | approval · regulatory CVA model + sensitivities |
Choice is strategic: BA-CVA punishes unhedged directionality; SA-CVA rewards a genuine CVA desk with model and data investment.
| Counterparty sector | IG | HY / NR |
|---|---|---|
| Sovereigns, central banks, MDBs | 0.5% | 2.0% |
| Local govt · govt-backed non-fin · education · public admin | 1.0% | 4.0% |
| Financials (incl. govt-backed) | 5.0% | 12.0% |
| Basic materials · energy · industrials · agri | 3.0% | 7.0% |
| Consumer goods/services · transport | 3.0% | 8.5% |
| Technology · telecoms | 2.0% | 5.5% |
| Health care · utilities · professional services | 1.5% | 5.0% |
| Other | 5.0% | 12.0% |
| Single-name hedge correlation rhc | |
|---|---|
| References the counterparty directly | 100% |
| Legally related entity | 80% |
| Same sector & region | 50% |
| 1 Counterparty credit spreads | the CVA-specific class |
| 2 Reference credit spreads | exposure-side |
| 3 Interest rate · 4 FX · 5 Equity · 6 Commodity | exposure-side |
Legacy note: the mCVA multiplier was reduced from 1.25 to 1 and the BA-CVA DS = 0.65 introduced in the 2020 Basel targeted revisions — both carried into CRR3. Numbers quoted from pre-2020 impact studies overstate CVA charges.
| BI ≤ €1bn | 12% |
| €1bn < BI ≤ €30bn | 15% |
| BI > €30bn | 18% |
Worked examples → section detail ⧉.
Worked examples → section detail ⧉.
| RW floor — senior / STS senior | 15% / 10% |
| Resecuritisation floor | 100% |
| Overall cap | ≤ K of underlying pool (senior look-through) |
| Output-floor S-TREA TRANS | SEC-SA p halved: 0.5 · STS 0.25 |
| Category | Treatment |
|---|---|
| Tokenised traditional assets | as underlying |
| ARTs backed by traditional assets | 250% |
| Other (incl. unbacked) | 1250% + exposure limit |
Worked examples → section detail ⧉.
| Date | Change |
|---|---|
| 01·01·2027 | Floor x → 60% · FRTB own funds apply (Art 495v multiplier option to end-2029) · CRD6 third-country branch regime |
| 01·01·2028 | x → 65% |
| 01·01·2029 | x → 70% |
| 01·01·2030 | x → 72.5% steady state · equity RW phase-in complete · FRTB multiplier expires |
| 31·12·2032 | Floor transitionals lapse: mortgage 10/45% split · unrated-corporate 65% · halved p-factors |
Worked examples → section detail ⧉.
Every layer is a % of the floored TREA (02) — which is how the output floor quietly raises the whole tower, not just the minimum.
Worked examples → section detail ⧉.
| Institution class | Frequency |
|---|---|
| Large — listed | annual full · semi-annual subset · quarterly key metrics |
| Large — non-listed | annual full · semi-annual subset |
| Other — listed / non-listed | annual full · key metrics semi-annual / annual |
| Small & non-complex (SNCI) | annual key metrics only |
Prudential capital regulation answers one question: how much loss can this bank absorb before depositors, the deposit-guarantee scheme or the state absorb it instead? Everything on this chart is machinery for that answer. The denominator (sections 02–07) converts every exposure into a common risk currency — risk-weighted assets — so that a mortgage, a swap, an operational failure and a securitisation tranche can be added together. The numerator (section 01) defines what counts as loss-absorbing. The ratios and buffers set how much of the latter must stand against the former, and Pillar 2 (section 08) patches what the standardised machinery cannot see.
The design tension running through all of it: risk sensitivity vs comparability. Sensitive measures (internal models) fit capital to actual risk but destroy comparability and invite gaming; crude measures (leverage ratio, SMA, output floor) are comparable and robust but misprice individual portfolios. Basel III's finalisation is best read as a deliberate rebalancing from the first toward the second, after two decades of drift the other way. Where a rule seems clumsy, look for the comparability argument — it is usually there.
Level 1: the CRR (directly applicable regulation — the calculations) and the CRD (directive — supervision, buffers, governance, transposed nationally). Level 2: Commission delegated and implementing acts, mostly drafted by the EBA as RTS/ITS — where the operational detail lives. Level 3: EBA guidelines and Q&As — formally comply-or-explain, practically binding. A CRR article is the start of the law, rarely the end of it.
Every number above has its own section on this chart; the pipeline is the claim that they compose.
| Block | Direction of travel |
|---|---|
| Credit SA | More risk-sensitive (to serve as a credible floor) |
| Credit IRB | Constrained: scope cut, inputs floored |
| Market | Rebuilt (FRTB), own funds from 2027 |
| CVA | Internal models abolished |
| Op risk | One formula, models abolished |
| Aggregation | Output floor, single stack |
| Numerator | Essentially untouched |
Reg. (EU) 2024/1623 (CRR3) and Dir. (EU) 2024/1619 (CRD6); consolidated CRR text; EBA roadmap and Q&A tool; Basel framework texts (bcbs.org) for lineage. UK: PRA PS1/26 (Basel 3.1, 2027). US: re-proposed endgame (March 2026, in finalisation) — divergence is now a permanent feature, not a transition.
The numerator is the part of the framework CRR3 barely touched — the 2010–2019 architecture held. What changed around it is the denominator (this chart's sections 02–07) and, through the output floor's single stack, how far one TREA number propagates into every requirement built on it.
| Area | Change |
|---|---|
| Own-funds criteria | Substantively unchanged — the 2010 architecture held |
| Interaction | Single-stack output floor: floored TREA now drives P2R, buffers, MREL alike |
| Perimeter | Consolidation updates: fintech/ancillary undertakings, holding-company approval regime refinements |
Art 25–92a CRR; buffers Art 128–142 CRD; MREL Art 45 ff BRRD / Art 92a–92b CRR for G-SIIs; the EBA Own Funds and MREL RTS stack and its standing Q&A practice, which functions as case law for instrument terms.
Tiering orders claims by when they absorb loss. CET1 absorbs while the bank operates — no coupon promise, no maturity, no incentive to redeem. AT1 is the bridge: perpetual, coupons fully discretionary (and non-cumulative), converting or writing down at a 5.125% CET1 trigger — designed to recapitalise a going concern without a court. T2 absorbs only in gone concern, hence the five-year amortisation as it approaches maturity: absorbency you are about to repay is not absorbency. Above it all sits the bail-in stack (TLAC/MREL): enough loss-absorbing liabilities pre-positioned that resolution recapitalises the bank from its own balance sheet.
Deductions remove assets that vanish exactly when needed: goodwill and intangibles have no liquidation value; DTAs on losses need future profits a failing bank will not have; own shares and cross-holdings are double-counted capital; the IRB shortfall marks under-provisioning. The threshold mechanics (10% / 17.65%) tolerate small financial-sector holdings and temporary-difference DTAs at a 250% weight rather than full deduction — a negotiated softening, not a principle.
| Topic | Where the answer is |
|---|---|
| Instrument terms | EBA Own Funds RTS + the standing EBA Q&A practice — de facto case law |
| MREL calibration | SRB MREL policy (annual); LAA + RCA + market-confidence charge |
| AT1 post-2023 | Trigger and write-down mechanics now a disclosed pricing factor; EU statements reaffirmed creditor hierarchy |
Minima are cliff edges: breach them and the supervisory machinery of last resort starts. Buffers exist to put loss-absorbing distance above the cliff — capital a bank may consume in stress with consequences that are commercial (distribution caps via the MDA) rather than existential. Each layer answers a different question. The CCoB (2.5%, fixed) is the all-weather cushion. The CCyB is the macroprudential experiment: built when credit runs hot, released when stress arrives — the only buffer designed to go to zero on purpose, and the reason several authorities (the Netherlands at 2% among them) now hold a "positive neutral" rate in calm times: you cannot release what you never built. G-SII/O-SII buffers price systemic footprint (the higher of the two applies); the SyRB covers structural risks the others miss and stacks on top — in the Netherlands used sectorally against RRE concentration.
The unresolved debate is usability: in the pandemic, banks proved deeply reluctant to dip into buffers even when invited — MDA stigma and market expectations made nominally usable capital behave like a minimum. The macroprudential review keeps circling the obvious conclusion: more of the stack should be releasable (CCyB-like), less of it fixed.
| Topic | State |
|---|---|
| Positive-neutral CCyB | Spreading practice, not EU law — rates are national decisions with 12-month implementation lags |
| SyRB | Sectoral use (RRE) established; overlap control with Art 458 measures |
| Usability | Macroprudential review's standing item: shift weight from fixed to releasable |
Pre-2008 balance sheets ran 40–50× equity while reporting comfortable risk-based ratios — low risk weights, not low risk, did the work. The leverage ratio is the deliberate antidote: Tier 1 over a total exposure measure, no weights anywhere. Its virtue and its vice are the same property: it prices a bund and a bridge loan identically. That is why it is a backstop, calibrated (3%) to bind only when risk weights fall low enough to be suspicious — and why for low-RWA business models (Dutch mortgage banks pre-floor) it was for years the actual binding constraint.
The exposure measure is accounting-plus: derivatives enter via a modified SA-CCR (collateral recognition restricted — received collateral cannot shrink the balance sheet), SFTs add a counterparty add-on, and off-balance items convert at their credit CCFs with a 10% floor. G-SIIs carry a leverage buffer of 50% of their G-SII buffer, with its own MDA analogue.
Capital requirements price expected distributions of loss; they are nearly silent on the scenario where one counterparty takes a quarter of your Tier 1 with it. The large-exposures regime is that missing constraint: a hard limit — 25% of Tier 1 to any single client or group of connected clients, 15% between G-SIIs — that no risk weight, rating or profitability can relax. It is deliberately crude because concentration risk is deliberately simple: the failure of Herstatt, of Continental Illinois's oil-patch book, of every bank that discovered its ten largest names were secretly one name, is the same failure. The intellectual content of the regime sits almost entirely in one question: what is "one" counterparty? Control makes two entities one; so does economic dependence — the supplier who dies if the anchor client dies. The EBA's connected-clients guidelines are the case law of that question, and supervisors read group structures more sceptically than banks do.
By the early 2010s the Basel Committee's hypothetical-portfolio exercises had produced an uncomfortable result: identical portfolios, handed to different IRB banks, came back with risk-weighted assets differing by a factor of three to four. Some dispersion is legitimate — different data, different workout experience — but the studies showed a large residual that could only be modelling choice. Once that was public, the credibility of every model-based ratio was in question: 13% CET1 at one bank was simply not the same claim as 13% at another.
One hypothetical portfolio, four IRB banks — model RWA, indexed. Illustrative of the BCBS 2013 banking-book RCAP findings.
The floor does not fix the models; it caps how much they can matter. Internal approaches stay worth up to a 27.5% saving — enough to reward genuine risk management, not enough to make modelling the business model. The price is risk-sensitivity at the very low end, and that trade was made knowingly.
IRB mortgage bank, U-TREA = 60, S-TREA = 100 (both stable). Track = S-TREA; the black marker is U-TREA; the bar is x · S-TREA. The larger of the two is that year's TREA.
The switch year depends only on the ratio U/S — here 60%, so the floor binds from the first year x exceeds it.
| Before | Now |
|---|---|
| Basel I floor (Art 500, largely spent) — no meaningful RWA floor | Output floor on total TREA, phase-in 50→72.5% |
| IRB benefit unlimited in EU-specific requirements | Single stack: floor propagates into P2R, buffers, MREL |
| — | Transitional S-TREA calibrations to 2032 (mortgages, unrated corporates, p-factors) |
Art 92(3)–(7) and Art 465 CRR; disclosure in the revised Pillar 3 ITS; EBA monitoring reports track the bite per country. Review clauses cover the transitionals — extension requires new legislation, not a delegated act.
Basel's floor text is one sentence; the EU fight was about where the floored number goes. Under parallel stacks, the floor would have applied only to the Basel minimum — P2R, the CBR and MREL would have kept riding on unfloored, model-based TREA, quarantining the floor's effect to a number few requirements actually reference. The adopted single stack sends floored TREA into everything: minima, P2R (recalibrated once at the switch to avoid double counting), buffers, MREL, large-exposure bases. That single design decision is why the floor is a balance-sheet event rather than a disclosure footnote — and why the transitionals were the political price. The supervisor's counterpart obligation: P2R and nominal buffer amounts must not silently double-charge risks the floor now covers; the EBA monitors, and banks argue, precisely this.
The standardised tower is not "SA credit risk" alone: it is the standardised measure of every risk class — SA-CR (with the Art 465 transitional calibrations), SA-CCR, BA-/SA-CVA as applicable, SMA op risk, FRTB standardised market risk, and the securitisation hierarchy with halved p-factors. IMM, IRB and A-IMA banks therefore run two full production stacks forever. The floor is also computed at each level of application — group and relevant sub-levels — so the data must reconcile at every node.
| Transitional (S-TREA only) | Calibration | Until |
|---|---|---|
| Residential mortgages (conditions met) | 10% / 45% split at 55% ETV | 31·12·2032 |
| Unrated investment-grade corporates | 65% RW | 31·12·2032 |
| Securitisation p-factors | 0.5 non-STS / 0.25 STS | 31·12·2032 |
| Cap on floored TREA | ≤ 1.25 × unfloored | member-state option |
Basel I's four flat buckets invited arbitrage — keep what the buckets underprice, securitise the rest. Basel II's answer created the opposite problem: every optimistic parameter saved real capital, and the discipline meant to prevent it proved weaker than the incentive. Post-2008 evidence, and in the euro area the ECB's TRIM on-site inspection of internal models, confirmed unjustified variability, chronic low-default-portfolio problems and downturn parameters that were not downturn at all. The finalisation is best read as a partial withdrawal of the bargain: models stay where defaults are plentiful enough to learn from, and the standardised approach was rebuilt — LTV real estate, SCRA, transactors — to be a credible yardstick for the floor.
€300k loan · property €375k · ETV 80% · retail obligor
| Area | Change |
|---|---|
| SA real estate | Loan-splitting & ETV whole-loan tables; IPRE and ADC own classes; valuation capped at origination |
| SA counterparties | SCRA; CQS2 institutions 30%; due-diligence override; equity 250/400% (phase-in); subordinated 150%; UCC CCF 10% (phased) |
| IRB scope | A-IRB withdrawn for large corporates & institutions; equity out; partial use liberalised |
| IRB parameters | Input floors; F-IRB senior unsecured LGD 45→40%; 1.06 scalar deleted |
| CRM | Own-estimate volatility adjustments abolished; F-IRB secured LGD* recalibrated |
| New | Retail FX multiplier ×1.5 (Art 123a); crypto transitional (Art 501d) |
Art 111–191 CRR plus the Level 2 layer: EBA PD/LGD estimation and downturn GL (IRB repair), RTS on economic downturn, connected-clients GL, ECAI mapping ITS. For ECB banks, TRIM decisions remain binding model-by-model.
Risk weights get the attention; the exposure value quietly decides half the answer. For balance-sheet items EAD is carrying value net of provisions; for commitments it is a credit-conversion question — how much of the undrawn line will be drawn by the time trouble arrives (empirically: most of it, which is why the unconditionally-cancellable 0% became 10%); for derivatives it is a distribution question — what could this be worth when the counterparty fails.
The derivatives answer has its own history. The Current Exposure Method (1988) — MtM plus a notional add-on — survived twenty-five years because it was simple, and misfired throughout because the add-ons knew nothing of netting quality, margining or moneyness. SA-CCR (BCBS 2014, EU since 2021) rebuilt it: replacement cost that respects margin terms, PFE add-ons per asset class with supervisory factors, a multiplier rewarding over-collateralisation, and the α = 1.4 scalar carried over from IMM as a conservatism buffer — much criticised, still standing.
CRM philosophy: collateral and guarantees reduce loss only if legally enforceable, valued with haircuts for market and FX risk, and monitored. CRR3's notable turn: own-estimate haircuts abolished — one more model surface closed.
| Before | Now |
|---|---|
| CEM / Standardised Method | SA-CCR only (below thresholds: simplified/OEM) |
| UCC CCF 0% | 10% (phased) |
| Own-estimate haircuts | Abolished — supervisory haircuts only |
Basel I weighted by who (sovereign, bank, mortgage, other); Basel II added rated how (ECAI grades); CRR3's SA finally asks what and how risky — LTV bands for property, project phase for specialised lending, transactor behaviour for cards, assessed counterparty grades for unrated banks. The redesign had one strategic driver: the output floor needs a yardstick credible enough that being floored to it is defensible. A second driver is jurisdictional: the US cannot use external ratings (Dodd-Frank §939A), so the framework had to work both with ratings (EU: ECAI + due diligence) and without (SCRA) — the same rule text carrying two philosophies.
The due-diligence overlay is the quiet novelty: banks must assess whether the external rating flatters the obligor and may only adjust the weight upward. Mechanistic reliance on ratings — the 2008 charge — is now formally the bank's problem.
| Area | CRR2 → CRR3 |
|---|---|
| Mortgages | 35% flat → loan-splitting 20/75 or ETV whole-loan; IPRE own table |
| Banks | Unrated: flat by sovereign → SCRA A/B/C; CQS2 30% |
| Corporates | Unrated IG 65% only inside the floor transitional; SME 85% retained via factor |
| Retail | Transactor 45%; currency-mismatch ×1.5 |
| Equity/sub-debt | 100% → 250/400% (phase-in) / 150% |
| Off-balance | UCC 0% → 10% (phased); CCF ladder rebuilt |
The IRB formula is a single economic idea: portfolio losses driven by one systematic factor (the economy), with each obligor's sensitivity set by an asset correlation R. Conditional on a 99.9th-percentile bad year, the formula asks what default rate the portfolio suffers and charges capital for the unexpected part — expected loss belongs to provisioning, and the shortfall between EL and accounting provisions is deducted from CET1. Everything else on the panel is parameterisation of that idea: R falling with PD for corporates (bigger firms fail together, small ones idiosyncratically), fixed at 0.15 for mortgages (one housing market), 0.04 for QRRE; the maturity adjustment charging migration risk on longer paper; the 0.9997-style conservatism debates that never end.
The finalisation did not reject the model — it rejected estimating it where data cannot: entities with two defaults per generation (banks, mega-corporates) lost A-IRB; every surviving input gained a floor; and the 1.06 scalar — a 2004-era calibration patch — was finally deleted. What remains is the bargain Basel II should have offered: models where defaults are countable, discipline everywhere.
| Change | Effect |
|---|---|
| A-IRB withdrawn (large corp., institutions) | Own-LGD advantage gone where defaults are unobservable |
| Equity → SA | All internal equity models retired |
| Input floors | PD 5bp (10bp QRRE revolvers), LGD/EAD floors per class |
| 1.06 scalar deleted | −5.7% RWA on all IRB books, mechanically |
| F-IRB senior unsecured LGD 45→40% | Partial offset to the constraints |
| Partial use liberalised | Permanent SA carve-outs by class without losing IRB elsewhere |
A bank holding €100m of corporate bonds and a bank holding €100m of a fund that holds corporate bonds own the same risk; the CIU framework exists to make their capital match — and to price the cases where they cannot be matched because the fund will not say what it holds. Hence the ladder: look-through (LTA) where holdings are known, position by position; mandate-based (MBA) where only the rules are known — capitalised as if the fund runs to the riskiest limits its mandate permits; fall-back (FBA, 1250%) where nothing is known. Two multipliers keep the incentives honest: fund leverage scales the exposures before weighting, and relying on a third party's calculation instead of your own costs a ×1.2 factor. The design turns transparency into a priced commodity — the manager's monthly data file is worth basis points of capital, and asset managers learned to sell it accordingly.
Post-2008 policy pushed derivatives into central clearing deliberately: netting multilateralised, margining standardised, contagion channels cut. The capital regime is the incentive half of that bargain — trade exposures to a qualifying CCP weight at 2%, an order of magnitude below bilateral — and the honesty half: clearing members mutualise each other's failures through the default fund, so default-fund contributions carry a charge keyed to KCCP, the hypothetical capital of the CCP itself, allocated pro rata. The unresolved question is the one the design created: CCPs are now the most systemic nodes in finance, and their own recovery-and-resolution regime is younger and less tested than the banks' one it was meant to protect. The 2% is a policy price, not a risk price — and everyone involved knows it.
2008 falsified 10-day 99% VaR comprehensively: trading losses exceeded years of accumulated market-risk capital, driven by what VaR ignores — the tail's depth beyond the quantile, evaporating liquidity, and credit warehoused at trading-book charges. Basel 2.5 (2009) patched with stressed VaR and the IRC; the FRTB rebuilt.
VaR reports the location of the tail; ES prices its average depth. Same book, very different incentives at the extremes.
IMCC avg €40m (last day €38m) · SES €15m · DRC €25m · mc = 1.7
OF = max(38+15, 1.7×40+15) + 25 = €108m. The multiplied average binds, as it usually does; SES and DRC sit outside the multiplier — hedging IMCC does not shrink them.
| Before | Now |
|---|---|
| VaR 99%, 10-day + stressed VaR + IRC | ES 97.5% stressed, liquidity horizons 10–120d, IMA-DRC |
| Bank-wide model approval | Desk-level approval, earned quarterly (PLAT, backtesting) |
| Intent-based boundary | Presumptive lists, reclassification lock, IRT desks |
| Old SA (building-block) | Sensitivities-based A-SA + DRC + RRAO; SSA for small books |
| All risk factors modellable | RFET; NMRFs charged via stress scenarios |
Art 325–325bp CRR; the three FRTB delegated acts (2024/2795, 2025/1496, June 2026 in scrutiny); RTS on PLAT, RFET/NMRF, backtesting; the EBA's August 2026 opinion on boundary/IRT and the 2027 start. UK: PS1/26 (IMA 2028). US: market risk confined to significant trading firms in the 2026 re-proposal.
The old standardised approach priced positions by notional buckets — blind to hedges, blind to curvature. The A-SA's insight is to charge capital on the same objects the front office already manages: delta sensitivities to prescribed risk factors, vega where there is optionality, and a curvature add-on that stress-shifts each factor up and down and keeps the worse residual beyond delta. Netting happens where risk actually offsets — within a bucket by supervisory correlation ρ, across buckets by γ — and because hedges can fail in both calm and panic, the whole aggregation runs three times (correlations ×1.00 / ×1.25 / ×0.75) taking the worst. DRC then charges default separately (sensitivities see spreads, not jumps-to-default), and RRAO sweeps up payoffs no sensitivity can represent. It is a model in standardised clothing — which is precisely why it can serve as everyone's floor and every desk's fallback.
| Old SA | A-SA |
|---|---|
| Notional blocks, crude offsets | Sensitivities, correlated aggregation, three scenarios |
| No curvature concept | Explicit curvature add-on |
| Specific risk charges | DRC on net JTD + RRAO |
The IMA's redesign is less about the risk measure than about accountability structure. ES at 97.5% calibrated to stress replaces VaR — pricing tail depth, scaled across liquidity horizons of 10–120 days so an exotic credit factor cannot pretend to index-future liquidity. But the deeper change: approval attaches to the desk, and stays only while the desk proves, every quarter, that the model's P&L is the desk's P&L (PLAT: Spearman correlation and KS-test between risk-theoretical and hypothetical P&L) and that exceptions stay countable (backtesting at 97.5% and 99%). Fail amber → capital surcharge; fail red → the desk falls back to A-SA. Risk factors themselves must earn modellability through real prices (RFET: 24 observations in 12 months, max gaps); the rest are charged as non-modellable via stress scenarios (SES) outside the diversification benefit. The 2008 problem — one bank-wide approval covering everything forever — is structurally gone.
| Basel 2.5 IMA | A-IMA |
|---|---|
| VaR + sVaR + IRC, bank-wide | Stressed ES + SES + DRC, per desk |
| 10-day everything | Liquidity horizons 10–120d |
| All factors modellable | RFET-gated; NMRFs to SES |
| Approval sticky | PLAT/backtesting quarterly; fallback priced |
Going into 2008, counterparty risk meant default risk. But a derivative claim on a weakening counterparty loses value long before any default: the credit valuation adjustment marks that expected-loss component to market, and in 2008–09 those marks moved violently. Supervisory post-mortems put roughly two-thirds of counterparty credit losses in the crisis on CVA mark-downs, only a third on actual defaults — and the framework charged capital exclusively for the third.
Composition of 2008–09 counterparty credit losses per BCBS post-crisis analysis — the empirical case for the CVA charge.
The CRR has exempted corporates, sovereigns, pension funds and intragroup counterparties from the charge since 2013 — an EMIR-aligned concession to end-user hedging that Basel never contained. CRR3 keeps the exemptions but makes them visible: exempted exposures must now be calculated and reported anyway. The Commission owes a review; the exemptions are the part most likely to move.
Add a 4y single-name CDS on the counterparty, notional €10m, rhc = 100%.
SNH = 1.00 × 5.0% × 4 × 10 × 0.906 = €1.81mHowever perfect the hedging, 25% of the unhedged charge survives — the β floor prices residual basis and model doubt.
| Before | Now |
|---|---|
| Advanced CVA (VaR-based, own models) + old standardised | Internal models abolished: SA-CVA (approval) / BA-CVA / simplified |
| Exemptions invisible | Exemptions retained but computed & reported |
| Basel 2017 calibration | 2020 recalibration: DS = 0.65 · mCVA = 1.0 · broader index hedges |
Art 381–386 CRR; EBA RTS on SA-CVA sensitivities and proxy spreads; the CCR inputs come from Part 3 Title II Ch 6 (03·A). Basel text: MAR50.
The BA-CVA is what remains when supervisors want CVA capital without CVA models: a closed-form approximation of a one-factor spread portfolio. Each counterparty gets a standalone charge (SCVA) proportional to risk weight × maturity × exposure; the aggregation then splits the book into a systematic component (spreads move together, ρ = 50% — hedgeable with indices) and an idiosyncratic component (they don't — hedgeable only name-by-name). Every design choice follows: single-name CDS reduce the name's own term with an rhc discount for basis; index CDS reduce only the systematic term; the HMA penalises hedges booked against the wrong name; and β = 25% floors the whole exercise because a supervisor who abolished CVA models does not then fully trust CVA hedge accounting either. The DS = 0.65 scalar is simply the 2020 recalibration admitting the 2017 numbers were too high.
| Old (CRR2 Art 384) | BA-CVA |
|---|---|
| Standardised CVA: bond-equivalent VaR formula | Portfolio-consistent SCVA aggregation, explicit hedge terms |
| Hedges crudely recognised | rhc ladder, index recognition, HMA, β floor |
SA-CVA is the compromise after IMA-CVA's abolition: banks may use their own exposure simulation and their own regulatory CVA function — risk-neutral, market-implied, own-default (DVA) excluded — but the capitalisation of its sensitivities is fully prescribed, SbM-style: delta and vega per risk class, supervisory risk weights and correlations, mCVA = 1. The prize is hedge recognition the BA-CVA cannot offer: market-risk hedges of the exposure component (rates, FX) count, not just credit hedges. The price is approval: a supervisor must accept the exposure models, the spread curves — including proxy spreads for the mostly-illiquid counterparty universe — and an active CVA desk. Regulatory CVA is deliberately not accounting CVA; reconciling the two is a standing governance exhibit.
Basel II's AMA let banks model operational risk with loss-distribution approaches, scenarios and correlation assumptions. The outcome was the credit-risk story in caricature: dispersion without credibility. Comparable banks held wildly different op-risk capital; the great post-crisis losses — LIBOR, FX-fixing, mis-selling, sanctions, US mortgage settlements, tens of billions each — arrived as litigation years after the conduct, in amounts no loss-distribution tail had contemplated. Modelling was measuring the past's noise while the actual risk was a legal process.
The SMA answer is deliberate crudeness: a single formula on income-statement scale (the BI), with coefficients rising in buckets. Basel's design lets a bank's own loss history modulate the result through the ILM; the EU set ILM = 1 — comparability over risk-sensitivity, the same trade as the output floor, made without apology. Loss history still matters twice: the ≥ €750m-BI bank must collect and disclose it, and Pillar 2 prices what Pillar 1 now refuses to model.
Marginal coefficients by BI bucket — crossing a threshold reprices only the increment, never the whole BI.
| Before | Now |
|---|---|
| BIA (15% GI) / TSA (12–18% by line) / AMA (own models) | One SMA: BIC on the BI, ILM = 1 |
| Loss data an AMA input | Loss data a universal obligation ≥ €750m BI, disclosed |
| Op-risk modelling for capital | Modelling survives only in Pillar 2 / ICAAP |
Art 312–324 CRR; EBA RTS/GL on the loss data set, BI mapping ITS; DORA (Reg. 2022/2554) for the ICT layer. Basel text: OPE25.
The SMA's design bets that operational risk scales with business volume, and that an income statement measures volume more honestly than any loss model. Each BI component is built to resist the obvious games: ILDC caps the interest margin at 2.25% of earning assets (else high-margin consumer lenders carry absurd op-risk capital); SC takes the max of income and expense (else outsourcing fees net away); FC takes absolute P&L (a loss-making trading year is not an op-risk holiday). The bucket coefficients are marginal, like income tax. Basel's ILM would then scale the result by loss history — the EU's ILM = 1 severs that link in Pillar 1, wagering that supervisors handle loss-sensitivity better through SREP than a formula handles it through a 10-year average. The wager is reviewable, and the EBA reports on it.
| Repealed | Replaced by |
|---|---|
| BIA (15% of gross income) | One SMA: BIC × ILM, ILM = 1 (Art 314(2)) |
| TSA (12–18% by business line) | |
| AMA (internal models) |
Under AMA, loss data fed capital models; the EU's ILM = 1 severed that link — and kept the dataset anyway. Deliberately: the loss register is the management-information core of operational risk (what actually goes wrong, where, how expensive), the disclosure raw material that lets markets compare conduct records, the Pillar 2 evidence base, and the option value of ever rejoining Basel's loss-sensitive mainstream. The regime's craft is in its details: events are recorded at ≥ €20,000 across ten years; each carries three dates (occurrence, discovery, accounting) because the misconduct wave's defining feature was lag — LIBOR conduct from 2005–09 hit P&L in 2012–15; related losses from one root cause are grouped as one event; and the boundary with credit risk (fraud in lending is credit RWA but op-risk registry) is a standing classification dispute with real consequences either way.
Pre-2008 securitisation ran on ratings arbitrage: originate-to-distribute pushed underwriting risk off the originator, tranching plus agency models manufactured AAA paper from subprime pools, and resecuritisation (CDO²) squared the error. When house-price correlation turned out higher than the models assumed, the AAA cliff-edge losses landed on holders whose capital charges had been near zero. The 2014 revised framework rebuilt the capital side — less mechanistic ratings reliance, the SEC-IRBA/-SA/-ERBA hierarchy, floors, and the p-factor as an explicit surcharge for tranching's model risk. The EU added the market-structure side in the 2017 Securitisation Regulation: risk retention, transparency, due diligence, and the STS label buying calibration relief for simplicity.
The standing tension: post-crisis calibration is widely argued to have over-corrected, and reviving EU securitisation is now industrial policy. The June 2025 Commission package proposes lower p-factors and lighter due diligence — in legislative process, worth tracking rather than assuming.
Art 501d is a transitional, not a framework: 250% for tokenised traditional assets and ARTs referencing traditional assets, 1250% for everything unbacked, pending a permanent BCBS SCO60-based regime. MiCA governs conduct; CRR prices the balance sheet.
Non-STS, p = 1, pool KA = 8%. Attachment/detachment on the vertical axis.
| Area | Change |
|---|---|
| Framework | Hierarchy unchanged (2019 architecture) |
| Output floor interaction | p halved in S-TREA: 0.5 non-STS / 0.25 STS — transitional to 2032 |
| Crypto | Art 501d transitional weights; disclosure & limits |
Art 242–270a CRR; Securitisation Regulation 2017/2402 (retention, transparency, STS); EBA SRT report and STS GL; ESMA disclosure ITS. Crypto: Art 501d CRR, MiCA, BCBS SCO60 pending transposition.
SEC-IRBA first: whoever can compute KIRB knows the pool best, and the p-factor even rewards that knowledge with a formula-driven p (a function of granularity N, LGD and maturity, floored at 0.3) usually below the SA's fixed 1.0. SEC-ERBA/IAA second: external or internal ratings where allowed — the EU inverted Basel's order here for rated positions, one of its quiet deviations. SEC-SA last: pool capital plus delinquency, no rating needed, p = 1. Below everything: 1250% for what cannot be assessed. The order is an information incentive — better data, lower p, less capital — which is also the honest reading of the June 2025 revival package: the EU deciding the information price was set too high for the market it wants.
Reference structure throughout: performing pool, average SA weight 100% → KSA = KA = 8%; under IRB the same pool yields KIRB = 6.5% (incl. expected loss). Tranches: junior 0–8%, mezzanine 8–16%, senior 16–100% — plus, for cross-approach comparison, one thick senior tranche attaching at 8%.
Same senior tranche, four answers. The ladder monetises information: loan-level knowledge (IRBA) or a rating (ERBA) each cut capital ~6× vs the formula-only SA on this structure. Floors: 15% (10% STS) apply throughout.
Non-STS, p = 1. The 8–100% comparison tranche averages ≈109% — it swallows the near-KA mass the 16% attachment escapes.
The EU legislated conduct first (MiCA: issuance, custody, stablecoin reserves) and prudential treatment second. Art 501d is the second — explicitly transitional: 250% for tokenised traditional assets and ARTs referencing traditional assets, 1250% for everything else, pending transposition of Basel's SCO60. SCO60 itself is the real architecture: Group 1a (tokenised traditional assets — weighted as the underlying, plus a discretionary infrastructure add-on), 1b (stablecoins passing the redemption-risk tests — reserve-based treatment), 2a (unbacked but hedgeable on deep markets — capped recognition of hedging), 2b (the rest — 1250%, i.e. deduction in disguise), with a Group 2 exposure limit: soft at 1% of Tier 1, hard at 2%. The design logic is symmetrical honesty: tokenisation of a bund is a bund; an unbacked token is capitalised as if it can go to zero, because it can.
Pillar 1 is deliberately incomplete: it standardises what can be standardised and leaves the rest — concentration, IRRBB, business-model risk, governance quality — to supervisory judgement. Pillar 2 is where that judgement gets teeth: the SREP turns assessment into P2R (binding, MDA-relevant, in the stack) and P2G (an expectation sized off stress tests, sitting quietly above it). The design question that never closes is double counting: as Pillar 1 grows more comprehensive — the floor, the SMA — P2R add-ons priced for the same risks must shrink, and demonstrating that is a standing negotiation between bank and supervisor.
IRRBB is the exemplary Pillar 2 risk: real enough to destroy banks (2023's US regional failures were IRRBB events), yet so dependent on behavioural assumptions — deposit stickiness, prepayment — that Basel rejected a Pillar 1 charge in 2016 and built standardised outlier tests instead. Pillar 3 completes the triangle: disclosure as discipline, now centralised in the EBA data hub so the market can actually compare what banks publish.
| Area | Change |
|---|---|
| SREP scope | ESG risks and transition plans enter the methodology; supervisory powers extended |
| Pillar 3 | Centralised EBA data hub; floor-split disclosure (U-TREA vs S-TREA); ESG templates |
| Perimeter | Third-country branch regime harmonised (CRD6) |
Art 73–110 CRD; EBA SREP GL (2022 revision); EBA IRRBB GL + RTS on the SOT and standardised methodology; Pillar 3 ITS. P2R/P2G decisions are bank-specific administrative acts — the law's last mile is your SREP letter.
The SREP scores four elements — business model, governance & risk management, risks to capital, risks to liquidity — each 1–4, composing an overall score that anchors P2R: a binding, MDA-relevant requirement covering risks Pillar 1 misses (concentration, IRRBB above the SOT's tolerance, model deficiencies, whatever TRIM left). Composition rule: at least 56.25% CET1 and 75% Tier 1, unless the supervisor demands more. P2G sits above the buffers: sized from stress-test depletion, not MDA-relevant, but ignoring it invites the one letter no CFO wants. The standing disciplines: no double counting with Pillar 1 (acute since the floor and SMA arrived — nominal P2R amounts were recalculated at the floor switch precisely to strip overlap), and proportionality (SREP intensity by category). ESG risks and transition-plan credibility enter the methodology from 2026 under CRD6.
ΔEVE revalues the whole banking book under rate shocks — the long-run solvency lens, punishing duration mismatch. ΔNII asks what happens to a year's earnings — the going-concern lens, punishing repricing gaps. They pull opposite ways: hedge the duration gap to protect EVE and you fix income streams that then miss rising rates in NII; run matched short books for NII and EVE barely moves but earnings whipsaw. Managing both is the actual craft of ALM, which is why Basel 2016 kept IRRBB in Pillar 2 with standardised outlier tests rather than a capital formula: the risk is real (2023's US failures were exactly unhedged EVE plus flighty deposits), but the numbers stand on behavioural assumptions — deposit cores, prepayment — no formula should pretend to own. The EBA's 2022 package added the NII SOT and standardised fallback methodologies for banks whose internal systems fail supervisory muster.
Pillar 3's premise is that markets punish what they can see; its history is the discovery that they can only see what is comparable. Free-form PDF disclosures failed that test, so the EU rebuilt the pillar as fixed templates (the EBA ITS: KM1 key metrics, OV1 RWA overview, CR/MR/OR detail, LR, LIQ, the MREL set), on fixed frequencies, scoped by proportionality (large listed institutions carry the full set; SNCIs a fraction), and — the current step — centralised into the EBA data hub: banks file once, machine-readable, and the EBA publishes, making cross-bank comparison a query rather than a project. Two live fronts: the floor split (U-TREA vs S-TREA disclosure makes every bank's model reliance public), and ESG templates (taxonomy alignment, transition exposure) — where disclosure is doing regulatory work capital rules have so far declined to do.