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Basel III SMA implementation tracker

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On 4 March 2016 the Basel Committee on Banking Supervision (BCBS) proposed a new Standardised Measurement Approach (SMA) for Pillar 1 operational risk capital. It proposed that the SMA replaces all existing basic, standardised and advanced approaches for calculating operational risk capital requirements. This tracker summarises plans for SMA implementation by jurisdiction.


The finalised guidance – published in December 2017 – offered national discretion on: 

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The use of loss data

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The use of loss data for small banks

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A higher threshold for which losses are included


The BCBS’ stated aim was achieve an appropriate balance between simplicity, comparability, and risk sensitivity for operational risk capital calculations. It also expected the revisions to have a relatively neutral impact on capital. 

We've previously done a number of detailed studies to assess the effect of the SMA on the industry, including a study on thecapital impact of the SMAwhich is freely available for you to read. We've also carried out a number of research projects for our members – including the capital benchmarking survey. 

ORX has also published a lessons learnt paper which has analysed the direction of travel of regulatory implementation around loss data quality, focusing on Canada where loss history has been included in the capital calculation.

As different regulatory bodies share their plans for Basel III, we'll update this page with information about their decisions and highlighting key areas of difference. If you have any updates please send them to john.bosnell@orx.org  

We will also have a standing item at the Banking Definitions Working Group looking at different national regulator requirements and guidance for the Internal Loss Multiplier component for Basel III SMA, if the regulator is not setting the loss multiplier = 1. 

The BCBS also publishes a progress report on the implementation of the Basel regulatory framework. The October 2024 press release has the latest detail on implementation in 27 jurisdictions and the European Union.

Summary of SMA implementation by jurisdiction 

Jurisdiction 
Implementation timeline for operational risk capital 
Loss History included 
Loss data for smaller institutions 

Australia (APRA) 

1 January 2023 

No 

No

 Brazil (BCB)

 1 January 2025 

 Yes 

No, or under guidance of the BCB for Segment 3 banks (Segment 4 & 5 banks set ILM = 1)

Canada (OSFI) 

1 February 2023 

Yes 

Only if approved for Standardised Approach 

Europe (EBA) 

1 January 2025 

No 

No

 India (RBI) 

Not confirmed 

Yes 

No for firms with BI of less than INR 80 billion 

 Japan (FSA) 

31 March 2024 (Internationally active) 31 March 2025  
(Non-internationally active) 

Yes 

No 

Singapore (MAS) 

 1 July 2024 

Yes

Optional for firms with a BI of less than SGD 1.5 billion

South Africa (SARB) 

1 July 2025 

Yes

No

Switzerland (FINMA) 

1 January 2025

Yes 

Yes, no exception in guidance

United Kingdom (PRA) 

1 January 2027

No

No 

United States (Fed) 

Not confirmed 

No, under consultation

No, under consultation 

Summary of differences in implementation and capital impact 

Australia (APRA)

Status:Confirmed, 12 June 2019 
Loss history included:No
Loss data for smaller institutions:  No 
Loss threshold: N/A  
Implementation timeline:  1 January 2023

BI buckets (for BIC calculation):

Bucket

BI range

Marginal coefficient (αi)

1

≤ $1.5bn

12%

2

$1.5bn < BI ≤ $45bn

15%

3

> $45bn

18%


Find out more
Brazil (BCB)

Status:  Confirmed, November 2023. 
Loss history included:  Yes  
Loss data for smaller institutions:  No, or under guidance of the BCB for segment 3 banks (Segment 4 & 5 banks don’t include ILM)
Loss threshold:  R$500,000 (~€77,950)
Implementation timeline:  1 January 2025

BI buckets (for BIC calculation):

Bucket

BI range

Marginal coefficient (αi)

1

≤ R$ 5bn

12%

2

R$ 5bn < BI ≤ R$ 150bn

15%

3

> R$ 150bn

18%


Comment

The BCB segments/buckets banks into segments based on the ratio of the total exposure of a financial institution compared to the Brazilian GDP as follows:

  • Segment 1 (S1)

    Large institutions (≥ 10% of GDP or with significant international activity).

    ILM is calculated normally, using the 10-year loss history.

  • Segment 2 (S2)

    Medium-to-large institutions (< 10% and ≥ 1% of GDP).

    ILM is calculated normally, using the 10-year loss history.

  • Segment 3 (S3) (or smaller)

    Medium institutions (< 1% and ≥ 0.1% of GDP).

    Default: ILM = 1

    Optional: May calculate ILM only with prior BCB authorisation, and the choice becomes irrevocable once approved, and it is only permitted starting 1 January 2028.

Find out more:

Currently no English translation exists of the BCB’s guidance on Basel III implementation:

Canada (OSFI)

Status:  Effective Nov 2023 / Jan 2024 via CAR Guideline; revised CAR (2026) effective Nov 2025 / Jan 2026.
Loss history included:  Yes 
Loss data for smaller institutions: Only if approved: Firms with Adjusted Gross Income < $1.5bn may apply to OSFI to apply the ILM if they have a minimum of five years of high-quality loss data. 
Loss threshold:$30,000 
Implementation timeline:  January 2025 

BI buckets (for BIC calculation):

Bucket

BI range

Marginal coefficient (αi)

1

≤ $1.5bn

12%

2

$1.5bn < BI ≤ $45bn

15%

3

> $45bn

18%


Comment

Category I Small and Medium Sized Deposit-Taking Institutions (SMSBs) must calculate Adjusted Gross Income at each fiscal year-end. If annual Adjusted Gross Income > $1.5bn, the firm most notify OSFI within 60 days of the end of the fiscal year and use the Standardised Approach (include ILM/loss history) for operational risk in the following fiscal year.

Once a Category I firm crosses the $1.5bn Adjusted Gross Income threshold, it must include loss history in its SMA calculation for a minimum of two years. If after two years, Adjusted Gross Income falls below $1.5bn, it must notify OSFI and may revert back to ILM = 1.

Find out more
Europe (EBA)

Status:  Fully implemented since 1st January 2025
Loss history included:No 
Loss data for smaller institutions: No 
Loss threshold:  EUR 20,000
Implementation timeline:  January 2025

BI buckets (for BIC calculation):

Bucket

BI range

Marginal coefficient (αi)

1

≤ €1bn

12%

2

€1bn < BI ≤ €30bn

15%

3

> €30bn

18%


Comment

Will require banks to systematically identify, disclose and manage Environmental, Social and Governance (ESG) risks, including climate stress testing.

Find out more
India (RBI)

Status:  Requirements issued, timeline for implementation not yet available 
Loss history included:  Yes 
Loss data for smaller institutions:  ILM=1 for bucket 1 banks with Business Indicator < ₹8,000 crore (approx. USD 1 billion) and for firms with inadequate loss data.
Loss threshold:  Not specified 
Implementation timeline:  Not specified

Comment:

RBI sets the marginal coefficient based on the BI buckets (in ₹ crore) as follows:

Bucket

BI range (₹ crore)

Marginal coefficient (αi)

1

≤ 8,000

12%

2

8,000 < BI ≤ 240,000

15%

3

> 240,000

18%


Banks which do not have 10 years of high-quality data but have five years of high-quality data can compute the Loss Component of the ILM with five years data instead. For banks that do not have 5 years of high-quality loss data, the ILM is not applied.

Find out more

Master Direction on Minimum Capital Requirements for Operational Risk (June 2023) 

Japan (FSA)

Status:  Confirmed and implemented
Loss history included:  Yes
Loss data for smaller institutions:  No (< ¥1 billion (~€6 million))
Loss threshold: Yes, ¥2 million (~€12 thousand)
Implementation timeline:  31 March 2024 (internationally active banks), 31 March 2025 (non-internationally active bank).  

BI buckets (for BIC calculation):

Bucket

BI range (JPY)

Marginal coefficient (αi)

1

≤ ¥100bn

12%

2

¥100bn < BI ≤ ¥3tn

15%

3

> ¥3tn

18%


Comment

The JFSA has gone ahead with the implementation of Basel III, even as other countries are holding back. 

Find out more

Currently no English translation exists of the FSA regulation:

Singapore (MAS)

Status:  Confirmed 
Loss history included: Yes 
Loss data for smaller institutions:  Banks with a business indicator under SGD 1.5 billion can use loss data or set ILM=1. All firms are required to disclose loss history
Loss threshold:  Losses equal to or over S$30,000 should be included in loss history
Implementation timeline: 1 July 2024

BI buckets (for BIC calculation):

Bucket

BI range

Marginal coefficient (αi)

1

≤ S$1.5 bn

12%

2

S$1.5bn < BI ≤ S$45bn

15%

3

> S$45bn

18%


Find out more
South Africa (SARB)

Status:  Confirmed, 22nd April 2024 
Loss history included:  Yes with floor (2025 – 0.95, 2026 – 0.9, 2027 – 0.85)
Loss data for smaller institutions:  No (BI < ZAR 5 billion)
Loss threshold:  ZAR 50,000 
Implementation timeline:  1 July 2025

BI buckets (for BIC calculation):

Bucket

BI range (ZAR bn)

Marginal coefficient (αi)

1

≤ 5

12%

2

5 < BI ≤ 150

15%

3

> 150

18%


Comment

The SARB has advised for banks to apply the ILM with a ILM floor of 0.95 initially which will be adjusted each year as follows: 

Implementation date ILM Floor
 1 July 2025 0.95
 1 July 2026  0.90
 1 July 2027 0.85

Find out more
Switzerland (FINMA)

Status:  Confirmed, 2022 
Loss history included:  Yes
Loss data for smaller institutions:  Yes, no exceptions specified
Loss threshold:  Losses over CHF 25,000 should be included in loss history
Implementation timeline:  1 January 2025

Comment:

No additional information regarding BI buckets. 

Find out more

Currently no English translation exists of FINMA’s guidance on Basel III implementation:

United Kingdom (PRA)

Status:  Confirmed, 20th January 2026
Loss history included:  No 
Loss data for smaller institutions:  The PRA considers that Basel 3.1 would be appropriate for all firms
Loss threshold:  N/A (ILM = 1)
Implementation timeline:1 January 2027

BI buckets (for BIC calculation):

Bucket

BI range

Marginal coefficient (αi)

1

≤ £0.88bn

12%

2

£0.88bn < BI ≤ £25.12bn

15%

3

> £25.12bn

18%


Find out more
United States (Fed)

Status:Re-proposal issued by Vice Chair for Supervision Barr in September 2024
Loss history included:No, under consultation
Loss data for smaller institutions:No, under consultation
Loss threshold:  Not specified 
Implementation timeline:  No indication

Comment

September 2024 re-proposal suggests no longer adjusting a firm’s operational risk charge based on its operational loss history. Explicit requirement to capture descriptive information about loss events greater than USD 20,000. Expecting another proposal to come in Q2 2026.

Find out more