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.
| 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 | 25% corporate unsecured · 5% retail mortgages · 10% real-estate-secured (non-retail) | 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.
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: Q4 2026.