CRR
More than seven years after the publication of the final Basel III reforms ("Basel IV") by the Basel Committee in December 2017, the EU implementation came into force on 1 January 2025 in the form of CRR III. It is a decisive milestone in the further development of European banking regulation. At the same time, it represents a preliminary finalisation of the regulations on capital and risk management. The focus is on risk-weighted assets (RWA), particularly for credit and operational risks, as well as the output floor, which is intended to limit the relief effects of internal models.
- Following publication in the EU Official Journal in June 2024, many banks have finalised their concepts and moved on to technical implementation. After banks worked flat out to submit the initial notification, implementation is now entering a stabilisation phase. This phase includes optimising technical solutions,
- the elimination of manual workarounds and
- preparing for external audits - in particular annual audits and special supervisory audits.
From spring 2026, the focus will increasingly be on the further development of CRR III implementation. Originally, a largely RWA-neutral transition was expected. However, initial surveys by the regulators (Quantitative Impact Study/Basel III Monitoring) show that The output floor in particular will lead to a significant increase in average core capital requirements in the European banking sector.
Although the burden will be extended until 2030 thanks to generous transitional provisions, it is already essential to integrate the effects into long-term capital planning. In particular, it is important to assess the consequences for product and borrower portfolios as well as risk-bearing capacity at an early stage.
A proactive analysis of the impact on capital costs and interest conditions is essential, especially for long-term financing - for example in the area of property financing.
Against this backdrop, institutions are already beginning to identify potential for optimising RWA and are planning to implement these successively after the stabilisation phase in order to meet regulatory requirements and ensure their long-term competitiveness.
At the same time, institutions are faced with a large number of new regulatory requirements introduced by the European Banking Authority (EBA) as part of CRR III. More than 140 level 2 mandates relate to key topics such as credit risk, market risk, ESG risks and governance. The EBA roadmap published in December 2023 sets out an ambitious implementation timeframe that will continuously present institutions with professional, procedural and technical challenges over the coming years.