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:
The use of loss data
The use of loss data for small banks
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 the capital impact of the SMA which 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 |
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 |
Summary of differences in implementation and capital impact
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
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:
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: 1 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
Status: Fully implemented since 1st January 2025
Loss history included: No
Loss data for smaller institutions: No
Loss threshold: EUR 20,000
Implementation timeline: 1 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
- Capital Requirements Regulation (CRR 3) for Basel III, see page 105 for calculation of the own funds requirement for operational risk pp 109-114 for loss data collection requirements.
- How will CRR3 reshape Pillar 1 capital in the EU?
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)
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:
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
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
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:
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
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.
