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 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 |
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
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
- APRA finalises new bank capital framework designed to strengthen financial system resilience
- APRA announces deferral of capital reform implementation
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
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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.
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- Proposed Capital Requirements Regulation (CRR 3) for Basel III, see page 28 for proposal to disregard historical loss data in calculation of own funds requirement, pp 137-148 for loss data collection requirements
- European Commission press release, timeline information
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
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- South African Reserve Bank Guidance Note (July 2021)
Status: Confirmed, 2022
Loss history included: Not specified
Loss data for smaller institutions: Not specified
Higher threshold: Not specified
Implementation timeline: 1 July 2024
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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
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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.
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- Basel III Endgame – Federal Reserve Board Meeting 27 July 2023
- Fed Basel III proposal (July 2023)
- Fed speech outlines future for loss data in US bank capital requirements
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
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Master Direction on Minimum Capital Requirements for Operational Risk (June 2023)
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