The International Banking Federation (IBFed) has published an updated review of Basel 3 and Basel 3.1 implementation, submitted to the Basel Committee on Banking Supervision (BCBS), urging annual assessments against the G20 objective of avoiding significant increases in overall bank capital requirements. Those assessments should capture the full capital burden, including national buffers, supervisory expectations affecting risk weights and requirements exceeding Basel minimums. Building on its May 2025 paper, the banking industry body argues that divergent use of discretionary national tools undermines comparability and creates uncertainty for banks’ capital planning.
The review incorporates the three U.S. capital proposals issued in March 2026, which replaced the 2023 proposal and remain unfinalized. The revised package narrows the mandatory scope of the expanded risk-based approach, but IBFed identifies remaining concerns about overlapping capital charges through stress testing and the treatment of nonbinding commitments. More broadly, it recommends a formal process requiring national additions to international standards to be transparently documented, justified, assessed for impact and periodically reviewed. Economic impact analysis should consider discretionary requirements alongside Basel minimums, including their effects on lending and clients such as small businesses and homebuyers. The recommendations renew the earlier paper’s call to balance financial stability with economic growth, rather than assessing prudential requirements in isolation.