The Ezelman GCC–EU Gap Monitor

Rule by rule, where are CBUAE, SAMA and QCB relative to the ECB/EBA stack? A one-pager that tells GCC risk leaders how much of Europe's regulatory future they need to start pricing in — and which bits are safe to ignore.

Rule-by-rule convergence, Q2 2026

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

Aligned Equivalent in letter and spirit Partial Core rule imported, edges differ Gap Material divergence — local approach Open Not yet published
Rule areaEU anchor🇦🇪 CBUAE🇸🇦 SAMA🇶🇦 QCB
Output floor (72.5%)CRR3 Art. 92 — fullPartial Phase-in to 2028AlignedPartial
SA-CR residential real estateCRR3 Art. 125 LTV bandsAlignedAlignedPartial
SA-CR unrated corporates100% standard + haircut logicGap Investment-grade due diligenceGap Local rating alt.Aligned
IRB PD input floorsCRR3 revised floorsPartialAlignedOpen
IRB LGD input floors5%/10% senior unsecured/mortgagesAlignedAlignedOpen
A-IRB scope limitationRemoved for large corp & FIGap Not yet restrictedPartialGap
CCF new buckets (off-BS)CRR3 Art. 111AlignedAlignedPartial
SA-CCRMandatoryAlignedAlignedAligned
Op risk — BICCRR3 BIC replaces AMAAlignedAlignedAligned
FRTB (market risk)CRR3 — SA + IMAPartial SA onlyPartialOpen
CVA — SA-CVA / BA-CVABoth pathsAlignedPartialOpen
IFRS 9 ECL — SICREBA guidelinesAlignedAlignedAligned
ICAAP supervisory narrativeSREP Pillar 2AlignedPartialPartial
Climate & ESG riskECB guidePartialPartialOpen
Operational resilience (DORA-equivalent)DORAPartialPartialOpen
Pillar 3 disclosure templatesEBA ITSPartialPartialGap

What the convergence picture tells us

Because the map is more useful in the open.

Large generalist firms hold this information internally — not out of any bad faith, but because unpublished intelligence is priced higher than published intelligence. That is a perfectly rational commercial choice in a scale business. It does leave the client buying the same answer three times across three advisors.

Ezelman comes at this from a different angle: as a senior-only CRR3 and OSI specialist, we publish the map, let the market see who built it, and have the hard conversation about the terrain at a boutique-grade day rate.

How the Monitor is built.

The Gap Monitor is a rule-by-rule comparison between the EU CRR3 / EBA anchor and the published rulebooks of the three principal GCC supervisors. Each cell is an Ezelman assessment, not a supervisor statement.

EU anchors. Regulation (EU) 2024/1623 (CRR3), Directive (EU) 2024/1619 (CRD6), the EBA ITS on supervisory reporting, the ECB Guide on climate-related and environmental risks, the DORA Regulation (EU) 2022/2554.

GCC anchors. CBUAE Standards on Capital Adequacy and associated Supervisory Notices; SAMA Rules on Minimum Capital Requirements, SAMA stress-testing frameworks, SAMA ICAAP guidance; QCB Instructions to Banks and QCB circulars on capital, stress testing and IFRS 9 application. Where public GCC material lags the Basel IV final-rule package, the cell is marked “Open”.

Scoring. “Aligned” means equivalent in both letter and operational expectation. “Partial” means the core rule is in force but with a phase-in, a carve-out or a scope restriction relative to the EU anchor. “Gap” means material local divergence. “Open” means the GCC supervisor has not yet published a position.

What we do not do. We do not publish client-specific gap assessments or bank-by-bank exposure tallies. Consistent with our sitewide public-data policy: every figure on ezelman.com is either public-sourced, an estimate with stated methodology, or an anonymised mandate-derived benchmark.

Next edition: Q3 2026.

Need this mapped to your book?GCC Partner diagnostic — 30 min.
HM
Hannan Mohammad · Founder & Managing Partner, Ezelman20+ years on the regulatory front line at European G-SIBs.
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