02 · Output floor
Art 92(3)–(7) · Art 465 CRR
Purpose & history
The failure it answers
By the early 2010s the Basel Committee's hypothetical-portfolio exercises had produced an uncomfortable result: identical portfolios, handed to different IRB banks, came back with risk-weighted assets differing by a factor of three to four. Some dispersion is legitimate — different data, different workout experience — but the studies showed a large residual that could only be modelling choice. Once that was public, the credibility of every model-based ratio was in question: 13% CET1 at one bank was simply not the same claim as 13% at another.
One hypothetical portfolio, four IRB banks — model RWA, indexed. Illustrative of the BCBS 2013 banking-book RCAP findings.
Intent, in one line
The floor does not fix the models; it caps how much they can matter. Internal approaches stay worth up to a 27.5% saving — enough to reward genuine risk management, not enough to make modelling the business model. The price is risk-sensitivity at the very low end, and that trade was made knowingly.
How it was fought over
Requirements
What a bank must actually operate
Calculations
When the floor binds — the switch year, visually
IRB mortgage bank, U-TREA = 60, S-TREA = 100 (both stable). Track = S-TREA; the black marker is U-TREA; the bar is x · S-TREA. The larger of the two is that year's TREA.
The switch year depends only on the ratio U/S — here 60%, so the floor binds from the first year x exceeds it.
The cap, and the cliff
S-TREA: €18.5bn vs €10.5bn → €8bn difference → 72.5% × 8 = €5.8bn of TREA once the floor binds. That is the 2033 cliff in one number.
Changes & sources
CRR2 → CRR3
| Before | Now |
|---|---|
| Basel I floor (Art 500, largely spent) — no meaningful RWA floor | Output floor on total TREA, phase-in 50→72.5% |
| IRB benefit unlimited in EU-specific requirements | Single stack: floor propagates into P2R, buffers, MREL |
| — | Transitional S-TREA calibrations to 2032 (mortgages, unrated corporates, p-factors) |
Where the law lives
Art 92(3)–(7) and Art 465 CRR; disclosure in the revised Pillar 3 ITS; EBA monitoring reports track the bite per country. Review clauses cover the transitionals — extension requires new legislation, not a delegated act.
Open items
- The end-2032 cliff — the largest unpriced parameter in low-RWA capital plans.
- Leverage interaction: as floored RWA rise, some banks switch binding constraint from leverage to floor — plan both.
Independent analysis by Elderlake Partners, as at August 2026. Not legal, accounting or supervisory advice.