G-SIB Methodology Review: The 66% Banking Union Rule Up for Comment

On 16 October 2026 the Basel Committee on Banking Supervision opened a consultation under its G-SIB methodology review, asking whether to write its 2022 treatment of cross-border exposures inside the European Banking Union (EBU) into chapter SCO40 of the Basel Framework. Comments are due by 14 January 2027. The consultative document runs to ten pages and recalibrates nothing: the 66% recognition rate, the one-bucket cap and the rule that G-SIB classification is untouched all come from the agreement the Committee reached in May 2022.

For a G-SIB headquartered in the Banking Union, the bucket the Committee recommends to the Financial Stability Board (FSB), and with it the higher loss absorbency (HLA) requirement, can be set on a parallel score that recognises 66% of the score reduction from treating its intra-EBU exposures as domestic. That currently rests on supervisory judgement and a June 2022 ECB statement. The proposal moves it into the standard, into the G-SIB reporting instructions and into the GSIB1 disclosure template, with immediate effect once finalised.

For reporting teams at EBU banks the work includes reconciling established EU reporting fields with the Basel items and assessing the proposed incorporation of the parallel-score treatment into SCO40, the G-SIB reporting instructions and the GSIB1 template. EU reporting already carries Banking Union data items; the consultation proposes to formalise the 2022 treatment in the Basel text, and the proposed wording does not yet line up in every respect with itself or with the 2030 version of SCO40.

Related reading: G-SIB Window Dressing: Basel Moves Indicators to Annual Averages

Key dates in the G-SIB methodology review

The document names no first assessment exercise for the revised text, and it describes the parallel-score allocation as current practice, so the treatment itself does not wait for the consultation to close. What waits is its place in the written standard and in the reporting instructions.

How the parallel score works today

Under the 2022 agreement, a parallel set of G-SIB scores is calculated for EBU-headquartered G-SIBs. Those scores recognise 66% of the score reduction that would result from treating intra-EBU exposures as domestic. The ECB’s June 2022 annex gives the reduction a name, the Adjustment for STructural Regional Arrangements (ASTRA), and sets out a two-step method.

Step one is the ordinary exercise: the existing BCBS methodology produces a score for every bank in the sample. Step two applies only to EBU-headquartered banks. The two cross-jurisdictional activity indicators, claims and liabilities, are recomputed as if exposures to counterparties resident in EBU countries were domestic. Every other indicator keeps its definition.

The ASTRA is the standard score minus the recomputed score, and the score used for bucket allocation is the standard score minus 66% of the ASTRA. The ECB attributes the 66%, rather than full recognition, to the fact that some elements of the Banking Union remain to be accomplished.

The denominator moves as well

The detail that matters for anyone trying to estimate the number sits in the ECB’s formula. The recomputed indicator divides the bank’s cross-border exposures to non-EBU counterparties by a sample total from which the intra-EBU exposures of every EBU-headquartered bank have been removed. Non-EBU banks keep their exposures to EBU countries in that total. A bank therefore cannot reproduce its parallel score from its own books: it needs the sample-wide figure for intra-EBU exposures, which it can at best approximate from other EBU banks’ published disclosures.

The adjustment is also capped by construction. It can only come from the cross-jurisdictional activity category, which carries 20% of the overall score, split 10% to claims and 10% to liabilities under the SCO40 weighting table.

Three limits on the outcome

The parallel score feeds the bucket only when the relevant authority proposes it. Any downward adjustment is limited to a single bucket. And the parallel score has no effect on whether a bank is a G-SIB, or on the scores and buckets of banks headquartered outside the EBU. The ECB annex spells out the classification point: a bank identified as a G-SIB under the standard methodology remains one even if its ASTRA would take its score below the classification threshold.

Under the texts as written, that leaves the parallel score with one job: moving a bank that is already a G-SIB down by at most one bucket.

What the consultation would write into SCO40, the instructions and GSIB1

The proposal has three parts. First, a new section titled “Use of supervisory judgement to take into account the European Banking Union” would sit in SCO40 as paragraphs 40.30 and 40.31. Paragraph 40.30 defines the parallel scores and the 66% recognition, tied to the cross-jurisdictional activity indicator. Paragraph 40.31 carries the operating rules: allocation on the parallel score when proposed by the relevant authority, the one-bucket limit, and no effect on classification or on non-EBU banks.

Second, the G-SIB assessment reporting instructions would be updated. The instructions already contain a guide to calculating a bank’s score from the Basel reporting template; the consultation cites Appendix 6 of the instructions for the end-2025 exercise, dated January 2026. That guide would gain the parallel-score calculation, in line with the description EU authorities published in 2022.

Third, disclosure. A new paragraph 40.37 would say that, for banks headquartered in the EBU, the data items relevant for the parallel-score calculation are part of the cross-jurisdictional activity indicators and are disclosed accordingly. The GSIB1 template in disclosure chapter DIS75 would gain a matching sentence in its Content field.

The Committee says the revisions would apply with immediate effect once finalised because they formalise existing treatment. Comments go through the form linked from the consultation page and will be published on the BIS website unless the respondent asks for confidential treatment.

Some things are absent from the document. It proposes no different recognition rate and no different cap, and it adds no indicator beyond the two cross-jurisdictional ones. The paragraph that frames the whole section also stays as it is: SCO40 already says structural changes in regional arrangements, in particular in the Banking Union, “will be reviewed as actual changes are made”, and the proposed 40.30 cross-refers to that sentence.

Two wordings of the 66% in one document

Read the annexes side by side and the recognition rule is phrased two ways. Proposed SCO40.30 follows the ECB: the parallel scores recognise 66% of the score reduction that would result from treating intra-EBU exposures as domestic. The proposed GSIB1 Content line describes items for calculating parallel scores “that recognise the score reduction that would result from treating 66% of intra-EBU exposures as domestic exposures”.

Those two readings produce different numbers, because the cross-jurisdictional indicator is a ratio with a sample-wide denominator. A stylised case shows the size of the gap. The figures are illustrative and come from no bank or published dataset.

• An EBU bank has 100 of cross-jurisdictional claims, 60 of them on EBU counterparties. The sample total is 1,000, of which EBU banks’ intra-EBU claims are 200.
• Standard indicator score: 100 / 1,000 = 1,000 bp. With full recognition: 40 / 800 = 500 bp, a reduction of 500 bp.
• SCO40.30 reading (66% of the reduction): 1,000 minus 330 = 670 bp.
• GSIB1 reading (66% of the exposures removed): 60.4 / 868 = about 696 bp.

On one indicator the readings sit about 26 bp apart. Because each cross-jurisdictional indicator carries a tenth of the overall score, that becomes roughly 2.6 bp on the overall score in this example, before the same effect on the liabilities indicator. Buckets are 100 bp wide above the 130 bp cut-off, so a few basis points only matter for a bank sitting close to a bucket boundary. For such a bank the wording decides the bucket.

The ECB formula, which the instructions are meant to follow, subtracts 66% of the full-recognition change. The GSIB1 sentence reads differently on its face, and the consultation does not say which wording governs; the difference may be loose drafting, which is an interpretation, not stated text.

The EU rules that already carry the Banking Union items

EU law got to the Banking Union treatment before the Basel text did, and from a different angle. Directive (EU) 2019/878 inserted paragraph 2a into Article 131 of the CRD, providing for an additional overall score, and gave competent or designated authorities a power in Article 131(10)(c): taking into account the Single Resolution Mechanism (SRM), they may re-allocate a G-SII from a higher sub-category to a lower one on the basis of that additional score. Recital 28 of the directive explains the purpose and its limits. The alternative score reflects progress on resolving cross-border groups within the Banking Union, it is calculated “without affecting the data supplied to the BCBS for the determination of international denominators”, and the methodology is to be used solely for calibrating the G-SII buffer.

The Commission followed with Delegated Regulation (EU) 2021/539 of 11 February 2021, amending the EU G-SII identification standard in Delegated Regulation (EU) No 1222/2014; in the EBA’s description, a new paragraph 5a of Article 5 provides for the additional overall G-SII score that accounts for the Banking Union and the SRM within the cross-border activity indicators. The EBA then amended its guidelines on systemic importance indicators (EBA/GL/2020/14) on 29 September 2022, through EBA/GL/2022/12, adding paragraph 10a. EBA/GL/2023/10 later replaced that paragraph; as it now reads, data items relevant for calculating adjusted SRM cross-jurisdictional indicators for institutions headquartered in Member States participating in the SRM are part of the cross-jurisdictional activity indicators, are disclosed in accordance with paragraph 12, and are not ancillary or memorandum items. Proposed SCO40.37 reads almost the same.

The EBA’s December 2023 amendment, EBA/GL/2023/10, applying from 20 May 2024, left the SRM items in the Annex template under the memorandum and ancillary labels, so that banks following both Basel standards and EBA guidelines do not have to maintain two reporting and disclosure templates, while stating that under paragraph 10a those items are not to be regarded as memorandum or ancillary items.

The supervisory reporting side

Article 20 of Commission Implementing Regulation (EU) 2024/3117 requires quarterly consolidated supplementary G-SII reporting by EU parent institutions, EU parent financial holdings and EU parent mixed financial holdings where the group’s total exposure measure, including insurance subsidiaries, is at least EUR 125 billion and the EU parent, a subsidiary or a branch operated by either is located in a participating Member State under Article 4 of Regulation (EU) No 806/2014. A standalone institution meeting the same threshold and located in a participating Member State reports on an individual basis. Article 20(4) sets entry and exit arrangements tied to the leverage ratio exposure measure at the end of the accounting year: where that measure exceeds the threshold at the accounting year-end, reporting starts immediately and covers that year-end and the following three quarterly reference dates, and reporting stops where the measure falls below the threshold at the accounting year-end. Remittance dates are 1 July, 1 October, 2 January and 1 April.

In the version of the G-SII template introduced by Implementing Regulation (EU) 2021/451, a block of items “considering the European Banking Union as a single jurisdiction” sat in rows 0140 to 0170, covering total foreign claims on an ultimate risk basis, foreign derivatives claims on an ultimate risk basis, foreign liabilities on an immediate risk basis including derivatives, and the derivatives subset of those liabilities. Definitions align with the BIS international banking statistics guidelines, except that activity across participating Member States is excluded, so those states count as one jurisdiction. Implementing Regulation (EU) 2022/1994 later replaced those instructions with a three-row block in rows 0140 to 0160, without the separate derivatives subset. In the G 01.00 template in Section 11 of Annex I to Implementing Regulation (EU) 2024/3117, the corresponding block sits in rows 0140 to 0160 (total foreign claims on an ultimate risk basis, foreign derivatives claims on an ultimate risk basis, and foreign liabilities on an immediate risk basis including derivatives), with no separate row 0170.

For an EBU bank already inside these EU perimeters, the proposal appears to add no new data item on its face (an interpretation). The existing BCBS instructions already define SRM-as-one-jurisdiction data items in Section 21; the proposed change concerns formalising the parallel-score treatment within the methodology and associated reporting and disclosure provisions. Once the Basel threshold rises, the EU thresholds sit below it: EUR 125 billion for the CIR reporting and EUR 200 billion for the EBA disclosure guidelines, against a Basel reporting and disclosure threshold that rises to EUR 350 billion from the end-2026 exercise. Our article on the EBA 2026 O-SII list and buffer obligations covers the domestic systemic buffers that sit alongside the G-SII buffer in the same capital stack.

Which banks the proposal reaches

The parallel score itself applies to EBU-headquartered G-SIBs only. On the FSB’s 2025 list, published on 27 November 2025, seven of the 29 G-SIBs are headquartered in Banking Union countries. Two sit in bucket 2 (1.5%): BNP Paribas and Groupe Credit Agricole. Five sit in bucket 1 (1.0%): Deutsche Bank, Groupe BPCE, ING, Santander and Societe Generale.

Bucket 1 is a floor for this purpose. The parallel score cannot remove a bank from the G-SIB list, so no allocation based on it can fall below bucket 1. The FSB list shows final allocations, so an EBU bank listed in bucket 1 may already sit there because a one-bucket adjustment moved it down from bucket 2, and a bucket-2 bank may have moved down from bucket 3. That is an interpretation of the rules applied to the published list, not stated text. The FSB’s 2025 list does not say whether any EBU bank’s allocation was based on its parallel score, so the published buckets do not show which of the seven banks the adjustment affects.

The disclosure line reaches further. Proposed SCO40.37 speaks of “banks headquartered in the EBU”, and the GSIB1 Content field of “banks in the EBU”. As drafted in Annex 2, GSIB1 would be mandatory for banks that in the previous year were classified as G-SIBs, had a leverage ratio exposure measure exceeding EUR 350 billion, or were included in the assessment sample by supervisory judgement.

The EUR 350 billion figure comes from the amendment published the same day, which applies from 1 January 2027; the Basel text currently in force uses EUR 200 billion, so the applicable threshold depends on the assessment and disclosure reference period. An EBU-headquartered bank in that disclosure scope that is not a G-SIB would, on the text as drafted, disclose items feeding a score calculated only for G-SIBs. The consultation does not explain the difference in scope, and it does not reconcile “headquartered in” with “in”.

A US or UK G-SIB with a large euro-area subsidiary gets no parallel score; a US group, for instance, reports its indicators through the Federal Reserve’s FR Y-15 systemic risk report. Its claims on EBU counterparties stay cross-jurisdictional in its own score and remain inside the denominator used for EBU banks’ recomputed indicators. The same holds for an EU bank headquartered in a Member State outside the Banking Union.

Where the proposal meets the 2030 averaging text

The consultation’s Annex 1 is drafted against the version of SCO40 that applies from 1 January 2027 under the window-dressing amendments published the same day: the EUR 350 billion threshold appears at proposed 40.34 and the operational timetable (applies from 2027 on end-2026 data, HLA from 1 January 2029) at 40.38. The proposed 40.30 points to the cross-jurisdictional activity indicator as set out in SCO40.13 to SCO40.14, which is where those paragraphs sit in that version.

The final window-dressing amendments also publish a second version applying from 1 January 2030, and its numbering differs. In that version SCO40.13 is the national discretion to require higher-frequency averages and SCO40.14 deals with currency conversion. The reporting threshold moves to 40.35 and the timetable stays at 40.38 with new dates: applies from 2030 on end-2029 data, HLA from 1 January 2032. Unless the cross-references are renumbered when the two texts are merged, SCO40.30 would point at the wrong paragraphs once the 2030 version applies. The consultation does not show a consolidated version.

Averaging raises a related question. From the 2029 data year, cross-jurisdictional claims and liabilities are averaged over quarter-ends for all banks, and the averaging table states that data items it does not list follow the frequency of their indicator. Read together, the Banking Union items would be quarterly averages too. The consultation is silent on this, and the point is covered in our analysis of the window-dressing averaging rules. Whether the Committee confirms that reading in the final text is open.

Preparing the data check and the response

The first task is to reconcile the current EU Banking Union items with the SRM-specific items already defined in Section 21 of the BCBS assessment instructions, and then assess any changes introduced by the proposed parallel-score calculation guidance. In its 2022 annex the ECB identified the relevant Basel template items as GSIB1280 and GSIB1281 for cross-jurisdictional claims and GSIB1282 for cross-jurisdictional liabilities, in the template current at that time. The BCBS instructions for the end-2025 G-SIB assessment exercise, dated 20 January 2026, are available on the BIS website. Section 21 already defines SRM-as-one-jurisdiction items, including items 21.d, 21.e, 21.f and 21.f.(1), while Appendix 6 explains the standard score calculation. The corresponding cell identifiers in the end-2025 workbook should be confirmed directly against that workbook rather than inferred from the earlier template.

The second is the Pillar 3 GSIB1 disclosure. The draft asks EBU banks to present the parallel-score items as part of cross-jurisdictional activity. Under paragraph 10a, institutions headquartered in Member States participating in the SRM should already treat them as part of those indicators, so the gap to close is definitional: whether the Basel instructions, once updated, describe the items in the same way as the BIS-statistics-based EU rows. How competent authorities supervise Pillar 3 disclosures is itself under EBA scrutiny, as our article on the EBA Pillar 3 peer review sets out.

Third, internal estimates. Because the recomputed indicator uses a sample-wide denominator, an in-house parallel score needs a proxy for the intra-EBU total across EBU banks. The ECB’s 2022 statement says the adjusted scores of the relevant EBU-headquartered banks will be published as part of obligations under EU law. SCO40, in the paragraph the consultation renumbers as 40.33, lists what the Committee itself discloses: cut-off scores, bucket thresholds, denominators and banks’ indicators. The draft does not add adjusted denominators to that list.

Points respondents could raise follow from the text itself:

• aligning the GSIB1 Content line with the “66% of the score reduction” wording in SCO40.30;
• renumbering the SCO40.13 to 40.14 cross-reference against the 2030 version;
• clarifying whether “banks in the EBU” and “banks headquartered in the EBU” mean the same population;
• confirming the averaging frequency for the Banking Union items from the 2029 data year;
• publishing the adjusted denominators alongside the standard ones.

Each sits within the consultation’s scope, since all concern how the 2022 agreement is written into the standard.

Frequently Asked Questions

Could a parallel score come out higher than the standard score?

Arithmetically, yes. The recomputed denominator loses every EBU bank’s intra-EBU exposures, so an EBU bank whose cross-border book is mostly outside the Banking Union can end up with a larger share of the shrunken total than of the original one. In the stylised figures above, a bank with only 10 of its 100 claims on EBU counterparties would score 1,125 bp on the recomputed indicator against 1,000 bp on the standard one. The ECB annex and the draft SCO40 text only address downward adjustments, and allocation on the parallel score happens only when the relevant authority proposes it, so neither text describes an upward case.

Who is the “relevant authority” that proposes using the parallel score?

The draft paragraph 40.31 does not name it. The 2022 description of the method came from the ECB Governing Council, and in EU law the re-allocation power in Article 131(10)(c) CRD belongs to the competent or designated authority. Where no proposal is made, the bucket follows the standard score.

Does a parallel-score bucket also change the leverage ratio G-SIB buffer?

Under the Basel framework the leverage ratio G-SIB buffer is set at 50% of the bank’s risk-weighted HLA requirement, so a lower bucket carries a lower leverage ratio buffer as well. The EU counterpart is the G-SII leverage ratio buffer in Article 92(1a) CRR, which G-SIIs report in the leverage ratio template. The consultation leaves both buffer rules as they are and affects only which bucket is recommended.

Does the EU parent of a third-country group in the euro area get a parallel score?

The Basel parallel score is calculated for EBU-headquartered G-SIBs, which is a test applied to the G-SIB group as a whole. The EU supervisory reporting duty in Article 20 of Implementing Regulation (EU) 2024/3117 follows a different perimeter: EU parent institutions above EUR 125 billion with a presence in a participating Member State. Reporting the Banking Union items under EU rules therefore does not by itself mean a Basel parallel score exists for that entity.

Could the 66% change if the Banking Union is completed further?

The texts make no commitment to a figure. The ECB tied the 66% to elements of the Banking Union that remain to be accomplished, and SCO40 says structural changes in regional arrangements will be reviewed as actual changes are made. The consultation proposes no change to the rate.

When does a lower bucket from the parallel score take effect?

The FSB’s 2025 list notes that a lower loss absorbency level after a bucket decrease applies immediately unless national authorities use their discretion to delay the release (RBC40.6 of the Basel Framework), while a bucket increase applies from January fourteen months after the list. Nothing in the consultation treats parallel-score decreases differently.

Related Articles

• G-SIB Window Dressing: Basel Moves Indicators to Annual Averages: the averaging frequencies, the EUR 350 billion threshold and the 2028 parallel run finalised on the same day.
• FR Y-15 Reporting: The Fed’s Systemic Risk Report, Schedule by Schedule: how the US collects the same G-SIB indicators through its own report.
• EBA 2026 O-SII List: Which EU Banks Carry an O-SII Buffer: the domestic systemic buffer layer in EU capital stacks.
• SRB Resolution Reporting: RESOL 1 and RESOL 2 Under the New ITS: the resolution reporting that underpins the SRM progress the parallel score recognises.
• Basel III Implementation by 2027: What the BCBS Tally Leaves Out: how Basel standards reach banks only through local implementation.

Key Takeaways

• Comment window: 16 October 2026 to 14 January 2027; responses are published unless confidentiality is requested.
• Calibration is fixed in the draft: 66% recognition, one-bucket cap, no effect on G-SIB status or on non-EBU banks.
• The parallel score cannot take an EBU G-SIB below bucket 1 or off the list; the 2025 list does not show which of the seven EBU allocations already rest on it.
• Check the GSIB1 wording (“treating 66% of intra-EBU exposures as domestic exposures”) against SCO40.30 and the ECB formula (“66% of the score reduction”) before relying on either.
• Map the EU Banking Union items (rows 0140 to 0160 of template G 01.00 in CIR 2024/3117; rows 0140 to 0170 in the original CIR 2021/451 version, cut to rows 0140 to 0160 by CIR 2022/1994) to the existing Basel Section 21 SRM items (21.d, 21.e, 21.f and 21.f.(1)) and any parallel-score instructions that follow; the earlier template item identifiers are given in the preparation section above.
• For banks already in the CIR 2024/3117 Article 20 and EBA/GL/2020/14 perimeters, the proposal adds no new EU data item on its face (an interpretation); it formalises existing Basel treatment in the standard, the instructions and a disclosure line.
• Track the SCO40 renumbering: the draft cross-references fit the 2027 version, not the 2030 version.

Sources and References

• BCBS, Global systemically important banks: methodology review, consultative document, 16 October 2026: publication page and PDF
• BCBS, Instructions for the end-2025 G-SIB assessment exercise, 20 January 2026 (Section 21 and Appendix 6): PDF (listed on the reporting instructions page)
• BCBS press release, Basel Committee finalises measures to address window-dressing in the G-SIB framework and consults on G-SIB methodology review, 16 October 2026: bis.org
• BCBS, Global systemically important banks: revised assessment framework to address window dressing, 16 October 2026: bis.org
• BCBS press release, Basel Committee meets to advance supervisory and regulatory initiatives, 1 October 2026: bis.org
• GHOS press release, 9 March 2026: bis.org
• BCBS press release, 31 May 2022 (completion of the EBU targeted review): bis.org
• BCBS press release, 9 November 2021 (review process and EBU targeted review): bis.org
• Basel Framework, SCO40 Global systemically important banks (in force from 9 November 2021): bis.org
• BCBS, G-SIB cut-off score and bucket thresholds: bis.org
• ECB, Governing Council statement on the treatment of the European banking union in the assessment methodology for G-SIBs, 27 June 2022, with annex: bankingsupervision.europa.eu
• FSB, 2025 List of Global Systemically Important Banks, 27 November 2025: fsb.org
• Directive (EU) 2019/878 (CRD V), recital 28 and Article 1 amending Article 131 of Directive 2013/36/EU: EUR-Lex
• Commission Delegated Regulation (EU) 2021/539 amending Delegated Regulation (EU) No 1222/2014: EUR-Lex
• Commission Implementing Regulation (EU) 2024/3117, Article 20 and template G 01.00 in Section 11 of Annex I (authentic OJ PDF): EUR-Lex
• Commission Implementing Regulation (EU) 2021/451, Annex XXVII (historical G-SII template instructions as originally adopted, rows 0140 to 0170; Implementing Regulation (EU) 2021/451 ceased to apply from 1 January 2025 except for specified provisions and is repealed with effect from 31 December 2026): EUR-Lex
• Commission Implementing Regulation (EU) 2022/1994 amending Implementing Regulation (EU) 2021/451, replacement Annex XXVII (G-SII instructions, Banking Union rows 0140 to 0160): EUR-Lex
• Commission Implementing Regulation (EU) 2025/2475 of 8 December 2025 amending Implementing Regulation (EU) 2024/3117, Article 25 (repeal of Implementing Regulation (EU) 2021/451 with effect from 31 December 2026): EUR-Lex
• Regulation (EU) No 806/2014 of 15 July 2014 (Single Resolution Mechanism Regulation), Article 4 as referenced in Article 20 of Implementing Regulation (EU) 2024/3117 (participating Member States): EUR-Lex
• Regulation (EU) 2019/876 (CRR II), G-SII leverage ratio buffer: EUR-Lex
• EBA, Guidelines amending Guidelines EBA/GL/2020/14 on the specification and disclosure of systemic importance indicators (EBA/GL/2023/10), 20 December 2023: final report and guidelines page
• BCBS, RCAP assessment of the leverage ratio framework: Australia, October 2026 (description of the leverage ratio G-SIB buffer): bis.org
• Federal Reserve, FR Y-15 Systemic Risk Report (reporting form and respondent panel): federalreserve.gov

Before 14 January 2027: the reconciliation and the comment

The consultation formalises what EBU G-SIBs already live with, so the bucket arithmetic does not change on finalisation; what changes is the text. For EBU banks in the GSIB1 disclosure scope, the artifact to produce before the deadline is a mapping of the EU Banking Union items to the Section 21 SRM items and the parallel-score items, with a note on which 66% wording the bank’s own estimate follows. Whether to send the drafting points above to the Committee is a decision to take by 14 January 2027.

Disclaimer: The information on RegReportingDesk.com is for educational and informational purposes only. It does not constitute legal, regulatory, tax, or compliance advice. Always consult your compliance officer, legal counsel, or the relevant supervisory authority for guidance specific to your institution.