The Bank for International Settlements Financial Stability Institute has published an FSI Insights paper examining how capital requirements for global systemically important banks compare across jurisdictions. Using a harmonised data set drawn from public disclosures for 29 G-SIBs in seven jurisdictions over 2014 to 2025, the paper finds that Basel III minimum requirements are broadly consistent but overall risk-based and leverage requirements differ materially because authorities use national flexibility differently across buffers, Pillar 2 add-ons or guidance, systemic surcharges and exposure measurement. It also finds that Common Equity Tier 1 requirements are less dispersed than total capital requirements and that higher required capital ratios may partly offset less conservative risk-weighted asset calculations. The paper shows that the total risk-based capital stack ranges from four to eight elements across the seven jurisdictions. In 2025, non-minimum components added from 0.1 percentage points on average in one jurisdiction to 3 percentage points in another, while the CET1 portion of required ratios averaged about 8 to 11 percentage points across jurisdictions and total capital requirements averaged almost 12 to almost 17 percentage points. Differences partly reflect banks' systemic importance, including Basel III G-SIB buffers of 1% to 2.5% of risk-weighted assets and surcharges of up to 4.5% in one jurisdiction using a parallel method. The analysis also points to marked differences in RWA density, around 30% of total assets for G-SIBs in the European banking union, Canada, Switzerland, Japan and the United Kingdom, versus about 45% in the United States and 55% in China, alongside heterogeneous leverage ratio stacks and calibrations. The paper says current efforts to modernise national frameworks could simplify capital stacks but may also change cross-jurisdictional comparisons. It adds that Basel Committee work to improve access to published supervisory data should increase transparency over how different jurisdictions implement the framework.
Bank for International Settlements - Financial Stability Institute2026-07-08
Bank for International Settlements Financial Stability Institute compares G-SIB capital requirements and finds wide cross-jurisdictional differences
The Bank for International Settlements Financial Stability Institute published a paper comparing capital requirements for 29 G-SIBs across seven jurisdictions from 2014 to 2025. It finds that while Basel III minimums are aligned, overall risk-based and leverage requirements vary because of different buffers, Pillar 2 practices, G-SIB surcharges and RWA methodologies. The paper also points to evidence that higher capital ratio requirements may offset less conservative RWA measurement.