Basel III was published by the Basel Committee on Banking Supervision in November 2010, and was first scheduled to be introduced from 2013 until 2015. Implementation the Fundamental Review of the Trading Book (FRTB) has been completed only in some countries and is scheduled to be completed in others in 2025 and 2026. Implementation of the Basel III: Finalising post-crisis reforms (also known as Basel 3.1 or Basel III Endgame), was extended several times, and is now scheduled to go into effect on July 1, 2025 with a three-year phase-in period.[1][2][3][4][5][6][7]
A mandatory "capital conservation buffer" or "stress capital buffer requirement", equivalent to at least 2.5% of risk-weighted assets, but could be higher based on results from stress tests, as determined by national regulators.
Plus:
If necessary, as determined by national regulators, a "counter-cyclical buffer" of up to an additional 2.5% of RWA as capital during periods of high credit growth. This must be met by CET1 capital.[8]
It also requires minimum Tier 1 capital of 6% at all times (beginning in 2015).[8]
Common Tier 1 capital comprises shareholders equity (including audited profits), less deductions of accounting reserve that are not believed to be loss absorbing "today", including goodwill and other intangible assets. To prevent the potential of double-counting of capital across the economy, bank's holdings of other bank shares are also deducted.
Leverage ratio is calculated by dividing Tier 1 capital by the bank's leverage exposure. The leverage exposure is the sum of the exposures of all on-balance sheet assets, 'add-ons' for derivative exposures and securities financing transactions (SFTs), and credit conversion factors for off-balance sheet items.[10][11]
Basel III introduced a minimum leverage ratio of 3%.[12] The requirement acts as a back-stop to the risk-based capital metrics.
For typical mortgage lenders that underwrite assets of a low risk weighting, the leverage ratio will often be the binding capital metric.
The U.S. established another ratio, the supplemental leverage ratio, defined as Tier 1 capital divided by total assets. It is required to be above 3.0%.[13] A minimum leverage ratio of 5% is required for large banks and systemically important financial institutions.[14] Due to the COVID-19 pandemic, from April 2020 until 31 March 2021, for financial institutions with more than $250 billion in consolidated assets, the calculation excluded U.S. Treasury securities and deposits at Federal Reserve Banks.[15][13][16]
In the EU, the minimum bank leverage ratio is the same 3% as required by Basel III.[17]
The UK requires a minimum leverage ratio, for banks with deposits greater than £50 billion, of 3.25%. This higher minimum reflects the PRA's differing treatment of the leverage ratio, which excludes central bank reserves in 'Total exposure' of the calculation.[18]
Liquidity requirements
Basel III introduced two required liquidity/funding ratios.[19]
The "Liquidity coverage ratio", which requires banks to hold sufficient high-quality liquid assets to cover its total net cash outflows over 30 days under a stressed scenario. This was implemented because some adequately-capitalized banks faced difficulties because of poor liquidity management.[20] The LCR consists of two parts: the numerator is the value of HQLA, and the denominator consists of the total net cash outflows over a specified stress period (total expected cash outflows minus total expected cash inflows).[21] Mathematically it is expressed as follows:
Regulators can allow banks to dip below their required liquidity levels per the liquidity coverage ratio during periods of stress.[22]
The Net stable funding ratio requires banks to hold sufficient stable funding to exceed the required amount of stable funding over a one-year period of extended stress.
Liquidity coverage ratio requirements for U.S. banks
In 2014, the Federal Reserve Board of Governors approved a U.S. version of the liquidity coverage ratio.[20] The U.S. requirements are higher than the Basel III requirements based on the definitions of HQLA and total net cash outflows. Certain privately issued mortgage backed securities are included in HQLA under Basel III but
not under the U.S. rule. Conds and securities issued by financial institutions, which can become illiquid during a financial crisis, are not eligible under the U.S. rule. The rule is also modified for banks that do not have at least $250 billion in total assets or at least $10 billion in on-balance sheet foreign exposure.[23]
Counterparty risk: CCPs and SA-CCR
A new framework for exposures to CCPs was introduced in 2017.[12]
Capital requirements for equity investments in funds
Capital requirements for equity investments in hedge funds, managed funds, and investment funds were introduced in 2017. The framework requires banks to take account of a fund's leverage when determining risk-based capital requirements associated with the investment and more appropriately reflecting the risk of the fund's underlying investments, including the use of a 1,250% risk weight for situations in which there is not sufficient transparency.[24]
Limiting large exposure to external and internal counterparties
A framework for limiting large exposure to external and internal counterparties was implemented in 2018.[12]
In the UK, as of 2024, the Bank of England was in the process of implementing the Basel III framework on large exposures.[25]
Capital standards for securitisations
A revised securitisation framework, effective in 2018, aims to address shortcomings in the Basel II securitisation framework and to strengthen the capital standards for securitisations held on bank balance sheets.[26] The frameworks addresses the calculation of minimum capital needs for securitisation exposures.[27][28]
Rules for interest rate risk in the banking book
New rules for interest rate risk in the banking book became effective in 2018. Banks are required to calculate their exposures based on "economic value of equity" (EVE) under a set of prescribed interest rate shock scenarios.[29][30]
The quality, consistency, and transparency of the capital base was raised.
Tier 1 capital: the predominant form of Tier 1 capital must be common shares and retained earnings. This is subject to prudential deductions, including goodwill and intangible assets.
Tier 2 capital: supplementary capital, however, the instruments were harmonised.
Provided additional incentives to move OTC derivative contracts to qualifying central counterparties (probably clearing houses). Currently, the BCBS has stated derivatives cleared with a QCCP will be risk-weighted at 2% (The rule is still yet to be finalized in the U.S.)
Provided incentives to strengthen the risk management of counterparty credit exposures
Raised counterparty credit risk management standards by including wrong way risk
A leverage ratio was introduced as a supplementary measure to the Basel II risk-based framework.
Introduced additional safeguards against model risk and measurement error by supplementing the risk based measure with a simpler measure that is based on gross exposures.
A series of measures was introduced to promote the buildup of capital buffers in good times that can be drawn upon in periods of stress ("Reducing procyclicality and promoting countercyclical buffers").
Measures to address procyclicality:
Dampen excess cyclicality of the minimum capital requirement;
Promoted more forward looking provisions;
Conserved capital to build buffers at individual banks and the banking sector that can be used in stress; and
Achieved the broader macroprudential goal of protecting the banking sector from periods of excess credit growth.
Requirement to use long-term data horizons to estimate probabilities of default,
Advocates a change in the accounting standards towards an expected loss (EL) approach (usually, EL amount := LGD*PD*EAD).[35]
U.S. modifications
In the U.S., Basel III applies not only to banks but also to all institutions with more than US$50 billion in assets:
"Risk-based capital and leverage requirements" including first annual capital plans, conduct stress tests, and capital adequacy "including a tier one common risk-based capital ratio greater than 5 percent, under both expected and stressed conditions" – see scenario analysis on this. A risk-based capital surcharge
Market liquidity, first based on the United States' own interagency liquidity risk-management guidance issued in March 2010 that require liquidity stress tests and set internal quantitative limits.
The Federal Reserve Board itself conducts stress tests annually using three economic and financial market scenarios. Institutions would be encouraged to use at least five scenarios reflecting improbable events, and especially those considered impossible by management, but no standards apply yet to extreme scenarios. Only a summary of the three official Fed scenarios including company-specific information, would be made public but one or more internal company-run stress tests must be run each year with summaries published.
Single-counterparty credit limits to cut credit exposure of a covered financial firm to a single counterparty as a percentage of the firm's regulatory capital. Credit exposure between the largest financial companies would be subject to a tighter limit.
Early remediation requirements to ensure that financial weaknesses are addressed at an early stage. One or more triggers for remediation—such as capital levels, stress test results, and risk-management weaknesses—in some cases calibrated to be forward-looking. Required actions would vary based on the severity of the situation, but could include restrictions on growth, capital distributions, and executive compensation, as well as capital raising or asset sales.[36]
Timelines
Implementation by the Basel Committee on Banking Supervision
On 15 April 2014, the Basel Committee on Banking Supervision (BCBS) released the final version of its "Supervisory Framework for Measuring and Controlling Large Exposures" (SFLE) that builds on longstanding BCBS guidance on credit exposure concentrations.[37]
On 11 March 2016, the Basel Committee on Banking Supervision released the second of three proposals on public disclosure of regulatory metrics and qualitative data by banking institutions. The proposal requires disclosures on market risk to be more granular for both the standardized approach and regulatory approval of internal models.[38]
In January 2013, the BCBS extended not only the implementation schedule to 2019, but broadened the definition of liquid assets.[39]
In December 2017, the implementation of the market risk framework was delayed from 2019 to 2022.[40] Implementation of the Basel III: Finalising post-crisis reforms, the market risk framework, and the revised Pillar 3 disclosure requirements were extended several times, and is now scheduled to go into effect on July 1, 2025 with a three-year phase-in period.[4]
Capital requirements timeline
Date
Milestone: Capital requirement
2014
Minimum capital requirements: Start of the gradual phasing-in of the higher minimum capital requirements.
2015
Minimum capital requirements: Higher minimum capital requirements were fully implemented.
2016
Conservation buffer: Start of the gradual phasing-in of the conservation buffer.
2019
Conservation buffer: The conservation buffer was fully implemented.
Leverage ratio timeline
Date
Milestone: Leverage ratio
2011
Supervisory monitoring: Developed templates to track the leverage ratio and the underlying components.
2013
Parallel run I: The leverage ratio and its components must be tracked by supervisors but not disclosed and not mandatory.
2015
Parallel run II: The leverage ratio and its components must be tracked and disclosed but not mandatory.
2017
Final adjustments: Based on the results of the parallel run period, any final adjustments to the leverage ratio.
2018
Mandatory requirement: The leverage ratio became a mandatory part of Basel III requirements.
Liquidity requirements timeline
Date
Milestone: Liquidity requirements
2011
Observation period: Developed templates and supervisory monitoring of the liquidity ratios.
2015
Introduction of the LCR: Initial introduction of the Liquidity Coverage Ratio (LCR), with a 60% requirement. This will increase by ten percentage points each year until 2019. In the EU, 100% will be reached in 2018.[41]
2018
Introduction of the NSFR: Introduction of the Net Stable Funding Ratio (NSFR).
2019
LCR comes into full effect: 100% LCR.
Country-specific timelines of implementation
The Federal Reserve implemented the Basel III standards in the U.S., with some modifications, via a proposal first published in 2011.[42] Final rules on the liquidity coverage ratio were published in 2014.[43]
An OECD study, released on 17 February 2011, projected that the medium-term impact of Basel III implementation on GDP growth would be minimal, in the range of −0.05% to −0.15% per year.[47][48][49] Economic output would be mainly affected by an increase in bank lending spreads, as banks pass a rise in bank funding costs, due to higher capital requirements, to their customers. To meet the 2015 capital requirements, banks were estimated to increase their lending spreads on average by about 15 basis points. Capital requirements effective as of 2019 (7% for the common equity ratio, 8.5% for the Tier 1 capital ratio) could increase bank lending spreads by about 50 basis points.[citation needed] The estimated effects on GDP growth assume no active response from monetary policy. To the extent that monetary policy would no longer be constrained by the zero lower bound, the Basel III impact on economic output could be offset by a reduction (or delayed increase) in monetary policy rates by about 30 to 80 basis points.[47]
In the United States, higher capital requirements resulted in contractions in trading operations and the number of personnel employed on trading floors.[50]
Academics criticized Basel III for continuing to allow large banks to calculate credit risk using internal models and for setting overall minimum capital requirements too low.[52]
Opaque treatment of all derivatives contracts is also criticized. While institutions have many legitimate ("hedging", "insurance") risk reduction reasons to deal in derivatives, the Basel III accords:
treat insurance buyers and sellers equally even though sellers take on more concentrated risks (literally purchasing them) which they are then expected to offset correctly without regulation
do not require organizations to investigate correlations of all internal risks they own
do not tax or charge institutions for the systematic or aggressive externalization or conflicted marketing of risk—other than requiring an orderly unravelling of derivatives in a crisis and stricter record keeping
Since derivatives present major unknowns in a crisis these are seen as major failings by some critics[53] causing several to claim that the "too big to fail" status remains with respect to major derivatives dealers who aggressively took on risk of an event they did not believe would happen—but did. As Basel III does not absolutely require extreme scenarios that management flatly rejects to be included in stress testing this remains a vulnerability.
The Heritage Foundation argued that capitalization regulation is inherently fruitless due to these and similar problems and—despite an opposite ideological view of regulation—agree that "too big to fail" persists.[54]
Basel III was also criticized as negatively affecting the stability of the financial system by increasing incentives of banks to game the regulatory framework.[55] Notwithstanding the enhancement introduced by the Basel III standard, it argued that "markets often fail to discipline large banks to hold prudent capital levels and make sound investment decisions".[55]
The Institute of International Finance a Washington, D.C.–based, 450-member banking trade association, argued against the implementation of the accords, claiming it would hurt banks and economic growth and add to the paper burden and risk inhibition by banks.[62]
