On 20 October, the European Banking Industry Committee (EBIC) submitted a joint letter to the co-legislators asking for a postponement of the Basel III implementation date in the European Union. EBIC strongly supports the ongoing legislative process aiming at finalizing the Banking Package. Given the substantial and comprehensive nature of the forthcoming legislative changes brought about by CRR III, a minimum of 18 months between the publication of CRR III rules in the Official Journal of the EU and the effective implementation date of the new rules will be necessary. Assuming CRR III publication in the Official Journal by end of 2023, EBIC suggests an initial application no earlier than 1 July 2025. Any postponement in the publication would require a further commensurate shift in the CRR III application.

1. CRR III mandates the European Banking Authority (EBA) to undertake tasks related to over 70 Regulatory Technical Standards (RTS) and Implementing Technical Standards (ITS) (altogether the EBA has 127 mandates) which must be factored into banks’ implementation of CRR III. A number of the EBA standards and guidelines are of high importance and mandatory for banks’ CRR III implementation to succeed and for banks to start reporting under the new rules as of the first application date.

1. Besides the fact that EU institutions/supervisors need time to perform their legally established mandates, EU banks need a reasonable amount of time to transition to new regulations, allowing them to upgrade their systems and adapt to the new calculation and reporting requirements in a controlled manner.

2. There is also an issue of practical alignment between the supervisory reporting and the capital requirements – as the two cannot be decoupled and the banks cannot implement the requirements without the reporting, which takes time to set up.

Finally, a postponement would reflect the process in other Basel jurisdictions, such as the USA or the UK. Even if the Basel III framework may not be fully applied to all institutions in these countries, the postponement of the first application date has already been announced there.