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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 2022 report has 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 

Not applicable 

Canada (OSFI) 

1 February 2023 

Yes 

Only if approved for Standardised Approach 

Europe (EBA) 

1 January 2025 

No 

Unconfirmed 

South Africa (SARB) 

1 July 2025 

Unconfirmed 

Unconfirmed 

Switzerland (FINMA) 

1 July 2024 

Unconfirmed 

Unconfirmed 

United Kingdom (PRA) 

1 July 2025 

No

No 

United States (Fed) 

Phased in from 1 July 2025 to 30 June 2028 

Yes, under consultation 

No for firms with assets under USD 100 billion 

India (RBI) 

Not confirmed 

Yes 

No for firms with BI of less than INR 80 billion 

Singapore (MAS) 

1 July 2024 

Yes 

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

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 
Higher threshold:N/A  
Implementation timeline: 1 January 2023

Find out more

 

Canada (OSFI)

Status:Confirmed, 18 July 2019 
Loss history included: Yes  
Loss data for smaller institutions:  Smaller firms with Adjusted Gross Income below CAD 1.5 billion can use the Simplified Standardised Approach (no loss data component) or the Standardised Approach with OSFI approval
Higher threshold: Losses over CAD 30,000 should be included in loss history 
Implementation timeline: Fiscal Q2 2023 - February 1, 2023 for institutions with an October 31st year end and April 1, 2023 for institutions with a December 31st year end

Comment

Basel II standardised transition year in 2020 

Find out more

 

Europe (EBA)

Status:Confirmed, 2 July 2019. Implementation pushed back from January 2023 to January 2025 to allow firms to focus on managing risks stemming from the Covid pandemic
Loss history included:No 
Loss data for smaller institutions: No 
Higher threshold:Supervisors' discretion 
Implementation timeline: 1 January 2025 

Comment

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

Find out more

 

South Africa

Status: Confirmed, 2021 
Loss history included:  Not specified 
Loss data for smaller institutions: Not specified 
Higher threshold: Not specified 
Implementation timeline: 1 July 2025 

Comment

Consultation paper on implementation to be published Q4 2022 

Find out more
Switzerland

Status: Confirmed, 2022 
Loss history included:  Not specified 
Loss data for smaller institutions: Not specified 
Higher threshold: Not specified 
Implementation timeline: 1 July 2024 

Find out more
United Kingdom

Status: Confirmed, 2021 
Loss history included:  No 
Loss data for smaller institutions: the PRA considers that Basel 3.1 would be appropriate for all firms
Higher threshold: Not specified 
Implementation timeline: 1 January 2025 

Comment

Reasons given by the PRA for setting the ILM=1 are: 

  • The calculation of the ILM is non-linear – operational risk capital requirements increase more slowly as historical losses increase. The PRA considers that, particularly for situations of large historical losses, more flexible and risk-sensitive approaches are appropriate, including the PRA’s Pillar 2A methodology.  
  • Calculating capital requirements for operational risk is a significant challenge. The loss distribution is unusually ‘fat-tailed’, characterised by infrequent but very large losses, and there is a paucity of data. The PRA considers that low-probability high-impact events, given their heterogeneity, are generally not good predictors of other unlikely events and therefore future losses. In these situations, the ILM may not be sufficiently risk-sensitive. 
  • The PRA considers that the information value of operational risk losses generally diminishes over time as business models and lending activities change. The SA’s use of a 10-year window of unweighted past losses in the ILM could result in it being inappropriately affected by large historical operational risk losses near the start of the 10-year period that might be weak predictors of future losses.

See CP16/22, section 8.24 

Find out more

 

United States

Status: Proposal put out for consultation in July 2023, Consultation closes November 2023
Loss history included:  Yes 
Loss data for smaller institutions: For firms with Assets of under USD 100 billion, ILM = 1 
Higher threshold: Not specified 
Implementation timeline:  Phased transition during 2025-28 

Comment

Proposal includes plan to have the Internal Loss Multiplier with a minimum value of 1 (meaning inclusion of losses will never decrease capital). Explicit requirement to capture descriptive information about loss events greater than USD 20,000. 

Find out more

 

India

Status:  Requirements issued, timeline for implementation not yet available 
Loss history included:  Yes 
Loss data for smaller institutions: ILM=1 for firms with Business Indicator = INR 80 billion (approx. USD 1 billion) 
Higher threshold: Not specified 
Implementation timeline:  Not specified

Find out more

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

Singapore

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
Higher threshold: Not specified 
Implementation timeline: 1 July 2024

Comment

Implementation Timeline 

Response to Consultation Feedback (December 2020)