The Ezelman CRR3 Impact Index

An illustrative read on Day-1 CRR3 RWA uplift across European G-SIB portfolios — broken down by asset class, portfolio type and jurisdiction. Public sources: EBA Basel III monitoring reports, EBA CRR3 quantitative impact note, and the subset of European G-SIBs that have disclosed a CRR3 first-time-adoption RWA bridge in their FY2025 Pillar 3 or results press releases. Methodology at the foot of the page.

High-teens %
Illustrative Day-1 CRR3 RWA uplift · before management actions · derived from public Pillar 3 disclosures of European G-SIBs that have published an FY2025 CRR3 FTA bridge, and cross-referenced to the EBA Basel III monitoring exercise.

The EBA’s most recent Basel III monitoring report anchors the industry at roughly low double-digit pre-management-action RWA uplift. Individual G-SIB FY2025 disclosures sit materially above that anchor where the bank’s book is skewed to IRB corporate / unrated-SA / mortgage exposures. Methodology and sources at the foot of this page.

Signature one-pager · coming soon

Behind the headline: a qualitative walk-through of one G-SIB case

Anonymised European G-SIB. How the post-management-action number moved, the three levers that carried the weight, and the supervisory conversation that signed it off. Specific basis-point and euro outcomes withheld at client request.

CFO Capital-Impact Case · coming soon Publishing shortly — currently under review.

Breakdown by asset class

Day-1 RWA uplift on a constant-book basis. Illustrative ranges. Estimation method — the high end of each range is anchored to the highest Day-1 uplift disclosed by a European G-SIB for that asset class in its FY2025 Pillar 3 or results press release; the low end to the median of the EBA Basel III monitoring exercise; and the “observed skew” column notes where Ezelman mandate experience clusters within that range.

Asset classIllustrative Day-1 rangeEBA benchmark anchorEzelman mandate skew
Residential mortgages+15% to +25% ~+12%Upper half
Large corporates (IRB)+10% to +20% ~+9.5%Upper half
Specialised lending+10% to +18% ~+8%Upper half
SME corporates+8% to +14% ~+7.5%Mid-range
Unrated corporates (SA)+20% to +30% ~+14.5%Upper half
Banks & FIs+6% to +12% ~+6.5%Mid-range
Counterparty credit risk (SA-CCR)+8% to +16% ~+8%Mid-range
Operational risk (BIC)+3% to +6% ~+3%Mid-range
Output-floor bite (all-book)+4% to +8% ~+4.5%Mid-range

Why observed ranges run above the EBA benchmark

  • Selection bias — acknowledged. Banks hire us when their internal numbers are getting worse. Mandate books over-index on uplift.
  • Pre-management-action numbers. The ranges are Day-1, before repapering, portfolio re-segmentation, securitisation, and IRB permission refresh — the fixes that deliver a material share of CET1 back (order of magnitude is bank-specific and withheld).
  • Conservative IRB re-calibration. We anchor on the upper bound of the PD floor literature until the bank’s supervisor signals otherwise. Firms that anchor on the lower bound can find themselves facing a Pillar 2G surprise in year two.
  • Unrated corporate treatment. The SA risk weight for unrated corporates is where individual G-SIB Pillar 3 disclosures diverge most from the EBA aggregate — the EBA sample skews to G-SIBs with more rated names than European mid-tier banks actually have.

How the Index is built.

The CRR3 Impact Index is an illustrative reference built from three public-data streams, triangulated with Ezelman mandate observations to position where within each range a given portfolio is likely to land.

Sources. (i) The EBA Basel III monitoring exercise — aggregate RWA impact estimates for European banks; (ii) the FY2025 Pillar 3 reports and results press releases of the European G-SIB cohort that have published a CRR3 first-time-adoption RWA bridge (BNP Paribas, Deutsche Bank, Santander, UniCredit, Intesa Sanpaolo and peers); (iii) the EBA’s Impact analysis of the CRR3 prudential framework / final-package QIS notes, and Regulation (EU) 2024/1623 as the authoritative legal text. Every figure on this page is either (a) drawn from one of those sources, (b) an estimate with the method stated above, or (c) labelled as a mandate-skew observation.

What we do not do. We do not publish specific basis-point or euro outcomes from individual Ezelman client mandates. Those figures are withheld at client request, consistent with our sitewide public-data policy (every figure on ezelman.com is public-sourced, an estimate with stated methodology, or qualitative).

Deeper asset-class and jurisdiction analysis — with the EBA/Pillar 3 bridges walked at a single-bank level — is released to Ezelman Intelligence subscribers.

Next edition: Q3 2026, published end of September.

Want the full breakdown?By jurisdiction, size tier, and management-action playbook.
HM
Hannan Mohammad · Founder & Managing Partner, Ezelman20+ years on the regulatory front line at European G-SIBs.
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