In remarks at a seminar on the challenges and responses of modern international financial regulation, the China Banking and Insurance Regulatory Commission argued that progress toward cross-border equivalence has been meaningful but that the international framework is showing structural fractures. It called for a two-layer approach combining strict adherence to core standards such as capital adequacy and liquidity with room for “adaptive” national adjustments, while avoiding a regulatory race to the bottom. The speech highlighted several areas for supervisory focus. On implementation consistency, it cited a Basel Committee on Banking Supervision monitoring report indicating that deviations in the implementation of Basel III Pillar 3 disclosure requirements have reached a post-reform record. On countercyclical regulation, it referenced the Basel III countercyclical capital buffer range of 0–2.5% and noted that few jurisdictions have applied broad, system-wide countercyclical measures, with more common use targeted at individual institutions; it proposed assessing sustainability of business models, incentives and performance frameworks, and the adequacy and真实性 of preventive capital and provisioning buffers. On risk governance, it emphasised building internal risk-control “three lines of defence” through governance checks and balances (including firewalls between controlling shareholders and senior management), front/middle/back-office separation, and stronger market discipline via disclosure. For non-bank financial institutions, it pointed to Financial Stability Board data showing global non-bank financial assets above USD 256 trillion at end-2024, representing 51% of global financial assets and growing 9.4% year on year, alongside private credit exceeding USD 2 trillion, and argued for a more systematic, enforceable regulatory framework with clearly defined supervisory responsibility, scope and tools. It also flagged operational resilience challenges linked to digital and crypto assets, artificial intelligence-driven change, concentration risks from outsourcing to a small number of large providers, and non-traditional threats such as cyberattacks and climate risks.