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 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.