The Ezelman GCC–EU Gap Monitor

Rule-by-rule convergence, Q2 2026

Ezelman assessment based on live GCC mandate work and published supervisory guidance. Updated quarterly.

Rule area	EU anchor	🇦🇪 CBUAE	🇸🇦 SAMA	🇶🇦 QCB
Output floor (72.5%)	CRR3 Art. 92 — full	Partial Phase-in to 2028	Aligned	Partial
SA-CR residential real estate	CRR3 Art. 125 LTV bands	Aligned	Aligned	Partial
SA-CR unrated corporates	100% standard + haircut logic	Gap Investment-grade due diligence	Gap Local rating alt.	Aligned
IRB PD input floors	CRR3 revised floors	Partial	Aligned	Open
IRB LGD input floors	5%/10% senior unsecured/mortgages	Aligned	Aligned	Open
A-IRB scope limitation	Removed for large corp & FI	Gap Not yet restricted	Partial	Gap
CCF new buckets (off-BS)	CRR3 Art. 111	Aligned	Aligned	Partial
SA-CCR	Mandatory	Aligned	Aligned	Aligned
Op risk — BIC	CRR3 BIC replaces AMA	Aligned	Aligned	Aligned
FRTB (market risk)	CRR3 — SA + IMA	Partial SA only	Partial	Open
CVA — SA-CVA / BA-CVA	Both paths	Aligned	Partial	Open
IFRS 9 ECL — SICR	EBA guidelines	Aligned	Aligned	Aligned
ICAAP supervisory narrative	SREP Pillar 2	Aligned	Partial	Partial
Climate & ESG risk	ECB guide	Partial	Partial	Open
Operational resilience (DORA-equivalent)	DORA	Partial	Partial	Open
Pillar 3 disclosure templates	EBA ITS	Partial	Partial	Gap

What the convergence picture tells us

• The CBUAE is the most rule-for-rule aligned: if you are a UAE bank, treat a CRR3 gap as a timing question, not a substance question.
• SAMA is the most ambitious on IRB adoption and is actively pushing G-SIB-grade supervisory dialogue. Its stress-testing expectations are already at ECB quality.
• QCB is deliberately slower; the smaller banking system lets it watch Brussels settle before codifying. Do not assume it will stay that way — we expect accelerated convergence 2026–2028.
• The two open battlegrounds across all three: FRTB (market risk) and operational resilience / DORA-equivalents. Any bank with a meaningful trading book or cloud footprint should be instrumenting today.