Ten years after the final Basel III standards were agreed, the finishing line keeps moving - and the movement itself has become the story. Here is where the three major regimes actually stand in September 2026, and what a staggered rollout means for firms that trade across them.
Three regimes, three clocks
The same Basel III "finalisation" package - often labelled Basel IV, and in Europe CRR3 - is now landing on three different timetables. The direction of travel is identical everywhere; the dates are not, and that divergence is now a planning problem in its own right.
- European Union. CRR3 entered into application in January 2025, and the credit-risk and output-floor elements are being phased in as planned. The market-risk chapter, however, has slipped again: on 12 June 2025 the European Commission announced a further one-year postponement of the FRTB market-risk requirements, moving application to 1 January 2027, explicitly to preserve a level playing field while other jurisdictions recalibrate.
- United Kingdom. The Prudential Regulation Authority has pushed the Basel 3.1 package to 1 January 2027, with market-risk reporting requirements aligned to that date. In its July 2025 consultation (CP17/25) and the January 2026 final policy statement (PS1/26), the PRA went further on internal models: FRTB-IMA adoption in the UK is now expected from 1 January 2028 - a deliberate wait-and-see on the US rulemaking.
- United States. The July 2023 Basel III Endgame proposal - which would have lifted capital requirements by roughly 16% (about $160bn) across the largest banks - drew near-universal pushback. On 19 March 2026 the federal banking agencies issued a re-proposal: a single set of risk-based calculations, better recognition of diversification in market risk, a clearer path for robust internal models, and recalibrated operational-risk charges. Comments closed in June 2026, and Vice Chair for Supervision Michelle Bowman has signalled the ambition to finalise a rule by the end of the year.
What the re-proposal actually changes
For trading desks, the March 2026 US re-proposal matters less for its headline numbers than for its philosophy. The 2023 text was widely criticised for ignoring netting and hedging; the revised text explicitly aims to "measure market risk more accurately by properly accounting for diversification and facilitating firms' use of robust internal models." It also confronts the long-standing double charge between the stress capital buffer and the market-risk framework - the overlap issue that has distorted trading-desk capital for a decade.
For globally active banks, the practical consequence is a three-speed world: standardized market risk from 2027 in the UK and EU, internal models from 2028 in the UK, and a still-forming US regime that will not land before 2027 at the earliest. Japan moved in 2024; Hong Kong and Singapore in 2025; Australia targets 2026. A bank trading across these jurisdictions needs a capital capability that can be switched on per regime - not one monolithic model rebuilt at every delay.
The quiet constant: data granularity
One lesson cuts through every delay: each postponement has raised, not lowered, the bar on data. FRTB's risk-factor-level requirements - positions mapped to risk factors at trade level, full revaluation capability, five years of stressed history - are not affected by when the rules bind. Firms that used the 2024-2026 grace period to rebuild their data pipelines are now running capital calculations as a by-product of daily risk. Firms that waited are starting from scratch, with less runway.
Our view: treat the timelines as a range, not a date. Build to the strictest regime (FRTB-IMA, EU/UK), sequence delivery so the standardized approach is a deployable fallback rather than a compliance scramble, and let the data layer - not the model layer - absorb the regulatory churn.