Elderlake Partners

00 · The framework & the pipeline

CRR (Reg. 575/2013 as amended) · CRD · Level 2

Purpose & history

What the framework is for

Prudential capital regulation answers one question: how much loss can this bank absorb before depositors, the deposit-guarantee scheme or the state absorb it instead? Everything on this chart is machinery for that answer. The denominator (sections 02–07) converts every exposure into a common risk currency — risk-weighted assets — so that a mortgage, a swap, an operational failure and a securitisation tranche can be added together. The numerator (section 01) defines what counts as loss-absorbing. The ratios and buffers set how much of the latter must stand against the former, and Pillar 2 (section 08) patches what the standardised machinery cannot see.

The design tension running through all of it: risk sensitivity vs comparability. Sensitive measures (internal models) fit capital to actual risk but destroy comparability and invite gaming; crude measures (leverage ratio, SMA, output floor) are comparable and robust but misprice individual portfolios. Basel III's finalisation is best read as a deliberate rebalancing from the first toward the second, after two decades of drift the other way. Where a rule seems clumsy, look for the comparability argument — it is usually there.

How EU law is layered

Level 1: the CRR (directly applicable regulation — the calculations) and the CRD (directive — supervision, buffers, governance, transposed nationally). Level 2: Commission delegated and implementing acts, mostly drafted by the EBA as RTS/ITS — where the operational detail lives. Level 3: EBA guidelines and Q&As — formally comply-or-explain, practically binding. A CRR article is the start of the law, rarely the end of it.

Five accords in one line each

1988
Basel I — 8% of crudely weighted assets. The invention of RWA.
1996
MRA — market risk added; internal models (VaR) admitted for the first time.
2004
Basel II — risk sensitivity: IRB, op risk, three pillars.
2008
The test. Quantity, quality and credibility of capital all fail at once.
2010
Basel III — more and better capital: CET1, buffers, leverage, liquidity.
2017–19
Finalisation ("Basel IV") — credible measurement: constrained models, rebuilt standardised approaches, output floor.
2024–25
CRR3/CRD6 — the EU transposition this chart describes, applying from 1 Jan 2025 (FRTB own funds 2027).

Requirements

Framework-level obligations

Level of applicationRequirements bite at consolidated level and, by default, at individual level per institution; waivers (Art 7–9) need supervisory approval. Every figure on this chart exists per level of application.
Prudential consolidationThe prudential scope differs from IFRS consolidation (insurance out, some SPEs in). The reconciliation between the two is a standing Pillar 3 template and a recurring audit finding.
ProportionalitySmall and non-complex institutions (SNCI, Art 4(1)(145)) get simplified disclosure, reporting relief and the SSA/simplified approaches — a formal classification to be applied for, not assumed.
Reporting stackCOREP carries every calculation on this chart to the supervisor quarterly; FINREP feeds the BI and reconciliations. Data quality here is itself a SREP scoring element.
Governance of the pipelineSomeone must own each arrow on the front of this chart: model inventories, EAD hand-offs between engines, floor reconciliation — the interfaces fail more often than the engines.

Calculations

Reading the pipeline — one bank, end to end

Worked example — assembling TREA and the ratios Credit RWA (IRB + SA mix) €52bn · CCR €4bn · CVA €3bn · Market €6bn · Op risk €7bn → U-TREA = €72bn
All-standardised: S-TREA = €104bn · floor 2026: 55% × 104 = €57.2bn → TREA = max(72, 57.2) = €72bn (models still bind; from 2029, 70% × 104 = 72.8 → the floor takes over)
Own funds: CET1 €9.5bn · T1 €11.0bn · Total €12.2bn
Ratios: CET1 13.2% · T1 15.3% · TC 16.9% — against a stack of minima + P2R + buffers (08) and, in parallel, leverage: T1 / LREM €260bn = 4.2% vs 3%.

Every number above has its own section on this chart; the pipeline is the claim that they compose.

Changes & sources

CRR3 in one table

BlockDirection of travel
Credit SAMore risk-sensitive (to serve as a credible floor)
Credit IRBConstrained: scope cut, inputs floored
MarketRebuilt (FRTB), own funds from 2027
CVAInternal models abolished
Op riskOne formula, models abolished
AggregationOutput floor, single stack
NumeratorEssentially untouched

Sources

Reg. (EU) 2024/1623 (CRR3) and Dir. (EU) 2024/1619 (CRD6); consolidated CRR text; EBA roadmap and Q&A tool; Basel framework texts (bcbs.org) for lineage. UK: PRA PS1/26 (Basel 3.1, 2027). US: re-proposed endgame (March 2026, in finalisation) — divergence is now a permanent feature, not a transition.

Independent analysis by Elderlake Partners, as at August 2026. Not legal, accounting or supervisory advice.