Banking

Basel 3.1: what changes for UK banks in 2027

After three years of back-and-forth, the Prudential Regulation Authority has chosen the implementation date for Basel 3.1 to begin on 1 January 2027 via the soon-to-be updated PRA Rulebook. This will change how UK banks measure their risk-weighted assets to account for credit, market, and operational risk, and place a limit on the capital benefit of models developed internally.

In January 2026 the Prudential Regulation Authority (PRA) published its final Basel 3.1 rules. The date has slipped twice, from 2025 to 2026 and then to 2027, but this time the PRA has issued a rulebook rather than a proposal, which puts firms on a different footing from the previous two deferrals. UK banks now have a fixed date to work to: 1 January 2027.

What changes on that date is the arithmetic behind a bank’s capital requirement. Risk-weighted assets (RWA) are the measure that scales required capital to how risky a bank’s lending is. Under the revised rules they are recalculated, and the range of exposures a bank may model for itself is cut back. For most firms that means a substantial body of remediation work.

What is Basel 3.1, and who wrote it?

Basel 3.1 begins with the Basel Committee on Banking Supervision (BCBS), the global standard-setter for banking regulation. It is a committee of central bank governors and bank supervisors drawn from the major financial jurisdictions. It meets at the Bank for International Settlements (BIS) in Basel, Switzerland, which is why its rules are called "Basel" standards.

1

BCBS

Basel III, finalising post-crisis reforms (d424)

View source ↗

After the 2008 financial crisis, banks using their own internal ratings-based (IRB) models to calculate how much capital they needed were producing vastly different answers for similar portfolios. The Basel Committee said as much when it published the fix, describing the reforms as aimed at "reducing excessive RWA variability" and committing to keep monitoring how well they do it.1 That RWA variability meant banks with better (and often larger) risk modelling or quant divisions had lower capital requirement ratios and hence lower risk-weights.

The fix was published in "BCBS d424", also known as "Basel 3.1" or "Basel IV". It introduced three major changes:

  1. Output floor. A bank using internal models cannot calculate a capital requirement below 72.5% of what BCBS’s standardised approach would give. This caps the capital saving a bank can get from its own models.
  2. IRB restrictions. Banks can no longer use their own models for exposures to large corporates (those with turnover above £440 million) and financial institutions, though Foundation IRB remains available for both. Equity exposures lose internal models altogether: d424 provides that "all equity exposures are subject to the standardised approach".1
  3. Parameter floors. For portfolios where IRB is still permitted, minimum floors on submodels were set, so models cannot produce implausibly optimistic inputs to drive lower capital requirements.

So while the BCBS writes the screenplay, the PRA directs the UK production. It takes the BCBS script and translates it into rules that UK banks are legally required to follow. It does this through three avenues.

CP
Consultation Paper
How the PRA (or any regulator) asks the industry “what do you think?” before making a rule. It reads the responses, decides what to change, and publishes a Policy Statement.
PS
Policy Statement
The PRA making a decision. The end of a consultation: it proposed something, listened to feedback, and now says “here are the rules.” The PS explains what changed from the CP and why.
SS
Supervisory Statement
The PRA explaining how it will check you’re complying; its published marking scheme. Failing to meet it isn’t automatically a breach, but it means a very uncomfortable supervisory conversation.

The table below shows the timeline of the PRA’s consultation process, from first proposals to a final rulebook.

From first proposals to a final rulebook

The output floor: flooring for a level picture

The 72.5% output floor is the structural centrepiece of Basel 3.1. The output floor ensures that RWAs calculated using internal ratings-based (IRB) models cannot fall below 72.5% of the standardised approach (SA) equivalent RWAs.

72.5%
The output floor does not eliminate the value of internal models. It establishes a lower bound below which modelled RWAs cannot fall, creating a level playing field across firms with different modelling choices.

Three quantities of total risk-weighted assets (TRWA) do the work: S-TRWA (the standardised total), U-TRWA (the unfloored modelled total), and TRWA itself (the reported total). TRWA is whichever is higher: U-TRWA, or 72.5% of S-TRWA.

The floor sets a lower limit on modelled capital
2

PRA

PS9/24: Implementation of the Basel 3.1 standards, near-final part 2

View source ↗

The floor is not imposed in full from day one. PS1/26 phases the floor in from 1 January 2027, stepping it up each year until it reaches its fully loaded 72.5% on 1 January 2030.2 The UK path derives from a Basel calibration that steps up annually: d424 sets the floor at "50%" on first application, then 55, 60, 65, 70 and finally "72.5%", a 2.5-point last step rather than a five-point one.1 The runway is intended to give banks time to absorb the capital impact through time rather than scrambling to do a once-off balance-sheet adjustment.

Ultimately, the 72.5% output floor means banks cannot model their way to lower capital. A bank with highly optimised internal models that would otherwise produce low RWAs gets pulled back up to 72.5% of the standardised value. In practice, this caps the capital savings available from the IRB approach, which directly affects return on equity calculations and the business case for maintaining complex internal model infrastructure.

A new cast: which exposures keep internal models

The IRB approach still remains in Basel 3.1 but its scope is significantly reduced and input floors tightened.

Equity exposures are removed from IRB eligibility entirely and must be treated under the standardised approach: for that class there is no IRB option at all.1

Other classes face partial restrictions rather than outright removal. Exposures to financial corporates and large corporates retain Foundation IRB (F-IRB) but lose the Advanced IRB (A-IRB). Exposures to income-producing real estate (IPRE), which may include high-volatility commercial real estate (HVCRE), lose both IRB approaches and are pushed to the slotting approach, a simplified method that assigns exposures to supervisory risk-weight buckets rather than using the bank’s own estimates.

Basel 3.1’s IRB restrictions confine the full Advanced IRB benefit to retail portfolios, other general corporates, and certain specialised lending sub-classes.

Where each exposure class moves

What changes for credit, market and operational risk?

The credit risk SA is the most revised part, with risk weights that are more sensitive to borrower type and collateral quality.

3

PRA

PS1/26: Implementation of the Basel 3.1 standards, final rules

View source ↗
  • Small and medium-sized enterprises that fail the retail criteria fall into the corporate class, where unrated exposures carry a preferential SME weight below the general unrated-corporate weight.3
  • Residential real estate risk weights are now segmented by loan-to-value (LTV) bands.
4

Gini

Counterparty credit risk: the governance behind the capital number

View source ↗

Counterparty credit risk follows the same pattern, and our guide to counterparty credit risk sets out the governance behind that capital number.4 The Internal Model Method (IMM), which lets banks model exposure at default on derivatives and securities financing transactions, is retained, with tightened permission conditions. Because the floor bites on total risk-weighted assets rather than on each risk type separately, modelled counterparty exposure feeds the same calculation.

5

Gini

FRTB in the UK: the standardised-versus-internal-models choice

View source ↗

The Fundamental Review of the Trading Book (FRTB) is the market risk portion of Basel 3.1, and our FRTB guide covers the standardised-versus-internal-models choice it forces.5

Market
risk
The risk of losses from movements in market prices such as interest rates, credit spreads, equities, and foreign exchange.

The FRTB replaces the pre-financial crisis market risk framework with a clearer trading-book boundary and three tiered approaches:

  1. The Simplified Standardised Approach (SSA) is for banks with straightforward, limited trading activity. It uses simple, pre-set risk weights applied to broad categories of exposure. It is the least data-intensive option and is designed for firms where market risk is not a significant part of the business.
  2. The Advanced Standardised Approach (ASA) is for banks with more active trading books that do not have, or do not want, supervisory approval for internal models. It calculates capital by measuring how sensitive each position is to changes in market factors (interest rates, credit spreads, equities, foreign exchange, and commodities) and aggregating those sensitivities using regulatory correlation assumptions.
  3. The new FRTB-IMA (Internal Models Approach) is for banks that have received supervisory approval to use their own models.

The ASA and SSA come into force on 1 January 2027. The IMA follows a year later, on 1 January 2028.

The three approaches compared

Operational risk moves to a single standardised approach based on the business indicator: a three-year simple average of income and expense components calculated at the firm’s financial year end. The existing set of approaches, including the Advanced Measurement Approach (AMA), is withdrawn.

Rewriting where the rules live

Basel 3.1 is not the only reason UK capital rules change in 2027. Before Brexit, the Capital Requirements Regulation (CRR) sat alongside the PRA Rulebook as a separate but equally binding source of rules, and firms read both together. The CRR survived Brexit intact, which left the PRA unable to amend rules sitting in EU legislation as freely as it amends its own. So the PRA is moving the CRR’s rules across, in phases, timed to land with Basel 3.1 rather than disrupt firms twice.

Five policy statements land the change: three move the CRR across, and two make separate changes that arrive on the same day.

6

PRA

PS3/26: Restatement of CRR requirements for 2027 implementation

View source ↗
7

PRA

PS4/26: The Strong and Simple Framework, the simplified capital regime for small domestic deposit takers

View source ↗
8

PRA

PS15/26: Pillar 2A review, phase 1

View source ↗
  • PS12/25 (already in force since January 2026): capital definitions, own funds, and ECAI mapping.
  • PS3/26 (in force January 2027): the CRR restatement, carrying the credit risk supervisory statements and securitisation requirements into the Rulebook.6
  • PS14/26 (in force January 2027): the remaining CRR definitions, less the PD, LGD and conversion-factor definitions, which were carved out into PS1/26.
  • PS4/26 (in force January 2027): the Strong and Simple regime, which takes small domestic deposit takers out of the full Basel 3.1 scope entirely.7
  • PS15/26 (in force January 2027): phase one of the Pillar 2A review, adjusting Pillar 2A alongside the Pillar 1 changes so the two do not double-count.8

PS1/26 rewrites many of the same rules under Basel 3.1, and all of it takes effect on the same day, 1 January 2027.3 Policy statements explain what changed and why; the Rulebook is what you comply with. From January 2027 the Rulebook carries them all, and it is the only document a firm needs to read.

Curtain call for UK banks

The Basel standard was finalised in December 2017; the UK’s implementation of it has been in development since 2022. BCBS d424 was the screenplay, the PRA’s consultation cycle was the production process, and PS1/26 is the locked script. What UK banks receive now is not a draft but a finalised rulebook.

From 1 January 2027, the savings that banks could get from their own capital models are capped, with those models accepted in fewer places. The standardised approaches around them arrive in revised form. And the CRR moves into the PRA Rulebook, so a UK bank’s capital rules are both rewritten and re-homed on the same day. The only remaining part is how well-prepared UK banks are when the PRA calls action.

Frequently asked questions

When does Basel 3.1 take effect in the UK?

Basel 3.1 applies in the UK from 1 January 2027, the date the Prudential Regulation Authority confirmed in PS1/26. From that date the PRA Rulebook changes how risk-weighted assets are calculated for credit, market and operational risk, and limits where banks may use internal models. One exception runs a year later: the internal models approach for market risk applies from 1 January 2028.

What is Basel 3.1, and why is it also called Basel IV?

Basel 3.1 is the final package of post-crisis capital reforms published by the Basel Committee on Banking Supervision as BCBS d424, and it goes by Basel 3.1, Basel IV and the Basel endgame. It responded to a specific problem: banks using their own internal ratings-based models were producing very different capital answers for similar portfolios, which handed an advantage to firms with the largest modelling teams.

What is the Basel 3.1 output floor?

The output floor stops a bank using internal models from reporting risk-weighted assets below 72.5% of what the standardised approach would produce. It does not remove the value of internal models. It sets a lower bound beneath modelled results, which caps the capital saving available from the internal ratings-based approach and, with it, the business case for maintaining complex model infrastructure.

How is the output floor calculated?

Three quantities do the work. S-TRWA is the total risk-weighted assets under the standardised approach, U-TRWA is the unfloored modelled total, and TRWA is the figure reported. TRWA is whichever is higher of U-TRWA and 72.5% of S-TRWA. Where a bank's models produce a total above the floor, the floor does not bite and modelled numbers are reported as they stand.

Does the output floor apply in full from 2027?

No. PS1/26 phases the floor in from 1 January 2027 rather than imposing it at its full level on the first day, so banks can absorb the capital impact over several years instead of making a single balance-sheet adjustment. Firms should read the transitional provisions in PS1/26 for the level that applies in each year.

Which exposures lose internal model eligibility under Basel 3.1?

The internal ratings-based approach survives with a narrower scope and tighter input floors. Equity exposures lose IRB treatment and move to the standardised approach. Large corporates and financial corporates keep the Foundation IRB approach but lose the Advanced IRB approach. Income-producing real estate, which can include high-volatility commercial real estate, loses both and moves to the slotting approach, where exposures are assigned to supervisory risk-weight buckets rather than modelled. The full Advanced IRB benefit is left concentrated in retail portfolios and general corporates.

What are the three FRTB approaches to market risk?

The Fundamental Review of the Trading Book is the market risk part of Basel 3.1, and it offers three tiers. The Simplified Standardised Approach uses pre-set risk weights over broad exposure categories and suits firms where trading is not a significant business. The Advanced Standardised Approach measures each position's sensitivity to interest rates, credit spreads, equities, foreign exchange and commodities, then aggregates those sensitivities using regulatory correlations. The Internal Models Approach requires supervisory permission. The two standardised approaches apply from 1 January 2027 and the internal models approach from 1 January 2028.

What changes for operational risk capital?

Operational risk moves to a single standardised approach built on the business indicator, a three-year simple average of income and expense components measured at the firm's financial year end. The previous menu of approaches, including the Advanced Measurement Approach, is withdrawn, so modelling operational risk capital is no longer an option.

Why are UK capital rules moving into the PRA Rulebook?

Before Brexit the Capital Requirements Regulation sat alongside the PRA Rulebook as a separate but equally binding source, and firms read both together. The CRR survived Brexit intact, which left the PRA unable to amend those rules as freely as its own, so it is restating them in the Rulebook in phases timed to land with Basel 3.1 rather than disrupt firms twice. PS12/25 has been in force since January 2026, and PS3/26 takes effect in January 2027 alongside the Basel 3.1 rules themselves.

What is the difference between a consultation paper, a policy statement and a supervisory statement?

A consultation paper is how the PRA asks the industry for its view before making a rule. A policy statement is the decision that closes the consultation, setting out the final rules and explaining what changed from the proposals and why. A supervisory statement is the PRA explaining how it will assess compliance: missing it is not automatically a breach of the rules, but it invites a difficult supervisory conversation. For Basel 3.1 the sequence ran from CP16/22 in November 2022 through two rounds of near-final rules to the final rulebook in PS1/26.

Sources

  1. 1 BCBS. Basel III, finalising post-crisis reforms (d424) View source ↗
  2. 2 PRA. PS9/24: Implementation of the Basel 3.1 standards, near-final part 2 View source ↗
  3. 3 PRA. PS1/26: Implementation of the Basel 3.1 standards, final rules View source ↗
  4. 4 Gini. Counterparty credit risk: the governance behind the capital number View source ↗
  5. 5 Gini. FRTB in the UK: the standardised-versus-internal-models choice View source ↗
  6. 6 PRA. PS3/26: Restatement of CRR requirements for 2027 implementation View source ↗
  7. 7 PRA. PS4/26: The Strong and Simple Framework, the simplified capital regime for small domestic deposit takers View source ↗
  8. 8 PRA. PS15/26: Pillar 2A review, phase 1 View source ↗
Receive updates directly in your inbox

Stay connected