Post-Mortem: Basel IV & CRR3

• Global implementation remains fragmented, with divergence in implementation timelines and rules between major jurisdictions like the EU, UK and the US. Banks are often required to implement Basel IV locally first and then re‑engineer solutions for group‑level requirements.
• Output‑floor impacts will materially reshape capital positions, accelerating the need for proactive RWA management and more strategic portfolio decisions.
• Data architecture proved a decisive accelerator, with institutions treating data as engineered infrastructure moving faster and with fewer disruptions.

• Uncertainty around the Fundamental Review of the Trading Book (FRTB) is already influencing trading‑book composition, prompting banks to shift toward more liquid assets in anticipation of capital effects.
• US regulatory dynamics reinforce long‑term fragmentation, driven by structural differences in the banking system and diverging Basel endgame trajectories.

"Sometimes banks really had to implement Basel IV twice. Subsidiaries in places like Canada, Hong Kong, or Singapore had to implement early, while Basel IV was not yet implemented in Europe. When the group requirements came later, much of the local work wasn’t compatible because national discretions were used differently."

“It has a huge impact on cost and complexity when you implement something locally and then again at group level. That will increasingly be the cost of doing banking globally.”

Martin Neisen, Senior Partner, Governance, Risk & Compliance Division, Global Basel IV Leader, PwC Germany

"Those institutions that approached Basel implementation through a data‑architectural lens — understanding the structure of the data and the mechanics of storage, quality, and lineage — were faster off the block than those that focused only on templates."

Sidhartha Dash, Research Director, Chartis Research