Book a Demo
Most forward-looking pieces on bank capital are predictions dressed up as a schedule. This capital regulation outlook separates the two: what carries a date between now and 2030, what is judgment, and where nobody knows yet. As of October 2026 the dated part is short and crowded into one day, 1 January 2027. The rest of the decade hangs on a US final rule with no date and an EU legislative package with no text.
What is actually dated between now and 2030?
Rest of 2026. US agencies digest comments on the March Basel III endgame re-proposal (the comment period closed on 18 June). The Basel Committee owes an update on its cryptoasset review by year-end. EU co-legislators aim to close the securitization reform before 31 December.
1 January 2027. The most consequential date in the calendar. UK Basel 3.1 goes live, with the simplified regime for small domestic deposit takers and phase 1 of the PRA's Pillar 2A review. EU FRTB requirements become binding own funds, under the temporary relief in Delegated Regulation (EU) 2026/1221, published on 11 September 2026: a multiplier that scales the charge back toward pre-FRTB levels until the end of 2029. The EU output floor steps up to 60%, and on 11 January the CRD VI third-country branch regime applies.
2027. The Commission's first legislative banking package is expected in Q1. The PRA consults on phase 2 of its Pillar 2A review. US stress capital buffers stay frozen; under rules finalized on 30 September 2026, buffers from the 2027 stress test take effect on 1 January 2028 rather than 1 October.
2028. Basel's floor phase-in nominally completes and UK internal models for market risk go live. The EU floor reaches 65%. The Fed starts averaging two years of stress results, effective from 2029. The EU's CMDI reform largely applies from 11 May. The Bank of England reviews its MREL thresholds.
2029 to 2030. The EU market-risk relief expires at the end of 2029 unless extended. The EU floor reaches 72.5% in 2030 and the UK transition ends on 1 January 2030. The EU's floor transitionals for unrated corporates and mortgages run to 2032, and the Commission has already put them back on the table.
Note the shape: a cluster for 2027, a handful of items for 2029 and 2030. Anyone offering a detailed picture of 2029 is building it from something other than rulebooks.
Where does each jurisdiction stand in October 2026?
EU. CRR3 has applied since January 2025 (see what CRR3 changed). The Commission's 17 July communication on banking competitiveness promises proposals on the output floor and its transitionals, fewer buffers, and MREL closer to TLAC. It amends nothing by itself.
UK. The PRA's final Basel 3.1 rules (January 2026) confirmed the 2027 start with no substantive changes. The FPC cut its system-wide Tier 1 benchmark to around 13% in December 2025 (our note on the 13% assessment).
US. Delivered: the eSLR final rule (effective 1 April 2026), the community bank leverage ratio cut from 9% to 8%, and stress test transparency and buffer averaging. Still proposals: the endgame, the standardized approach amendments and the GSIB surcharge recalibration, all from 19 March. No agency has given a final date.
Switzerland. On 23 September the Council of States backed requiring UBS to back 90% of its foreign subsidiaries with CET1, short of the government's 100%. UBS puts the cost at about USD 16bn. The National Council is next; a final decision looks more likely in 2027.
How Do Capital Requirements Differ Across Basel, the EU, the UK and the US?
How do the six open files grade?
Does the Basel consensus survive implementation? Sourced in detail. Three calibrations on three timetables, with the EU and UK conditioning on the United States and the US conditioning on nobody; the Commission justified its FRTB relief by other jurisdictions' delays. Markers to watch: whether the US finalizes with market risk intact, whether peer reviews grade the packages honestly (the Basel Committee approved six leverage ratio assessments, including the UK and Switzerland, in September), and whether the next new standard can command implementation at all.
Buffer usability. The thinnest-sourced file. Two crises, no structural change. The EU's fewer-buffers agenda and the Fed's averaging, which it expects to roughly halve year-on-year swings, address simplicity and volatility, not whether banks will draw on buffers under stress. The test remains the next stress episode.
The AT1 question. Well bounded. A Swiss court annulled FINMA's write-down order in a first, partial ruling in October 2025; FINMA and UBS have appealed to the Federal Supreme Court, and the bonds stay written down meanwhile (see our Credit Suisse case study). Swiss lawmakers have since rejected letting AT1 cover half of the new subsidiary requirement. No EU, UK or US redesign of the instrument is on the table.
The floor becomes the frame. Sourced on dates and mechanism, judgment on consequence. As phase-ins complete between 2028 and 2032, standardized approaches increasingly set marginal capital for a widening set of European model banks, and the fight moves to standardized calibration (mechanics in RWAs and balance-sheet strategy under Basel IV). "A widening set": no population figure exists anywhere.
The deregulatory cycle. Where marking statuses matters most. Delivered: US leverage and stress-test relief, and the UK's higher MREL thresholds. Proposed only: the US endgame reduction and GSIB surcharge recalibration. Announced, not legislated: the EU competitiveness agenda. Two counterweights: the US re-proposal would end the AOCI opt-out for Category III and IV banks, and the positive-neutral countercyclical buffer is a standing tightening across Europe. Switzerland is tightening too.
The perimeter frontier. The most densely sourced file. The crypto standard entered the Basel framework in January 2026 and went under targeted review almost at once. Synthetic risk transfer has actually moved: the Committee's February 2026 analysis sized protected assets at about EUR 750bn, and the EU securitization reform in trilogue would replace mechanical risk-transfer tests with a principle-based one. Non-bank leakage is a stated concern without a test. Sovereign exposures and climate stay parked.
What can nobody tell you yet?
When the US finalizes, and when its rules apply. Large banks said on third-quarter earnings calls they hope for a final rule by year-end. That is expectation, not an agency commitment, and EU and UK sequencing hangs off it.
What the EU's Q1 2027 package contains. The communication names targets, not calibrations.
The peer-review verdict, and what buffer usability reform would look like. There is no proposal to describe.
A narrower fourth: which legal route extinguished Credit Suisse's AT1, the statutory regime or the instruments' own non-viability terms. The litigation turns on the legal basis of FINMA's decree, but the answer bears on pricing either way.
What actually decides the decade?
One rulemaking sets the anchor. A US final rule with market risk substantively intact is what the EU's end-2029 decision on its relief and the UK's model settings are waiting on.
The floor decides European lending economics, through the standardized calibration beneath it rather than the 72.5% headline. Standardized-approach lobbying may replace model approval as the industry's main capital workstream.
The next stress episode decides the buffer question, because it is the only test proposed that needs no rulebook change first.
Underneath it all is a reading rather than a proof: the plausible destination is not collapse but permanent calibration divergence under a shared vocabulary. Basel as grammar rather than law.
For the complete capital stack, from CET1, buffers and the output floor to Pillar 2 and MREL, and how Basel, the EU, the UK and the US implement them, see Mirai RiskTech's guide capital regulation across Basel, the EU, the UK and the US: a complete reference.
