Basel IV / CRR3 implementation from gap analysis to supervisory approval
End-to-end advisory on capital, liquidity, and governance frameworks. From Basel IV to BCBS 239, from EBA mandates to RWA optimisation. From technical design through supervisory engagement, we own the delivery to final approval.
Core Regulatory Programmes
The regulatory landscape is broad. Implementation requires simultaneous execution across credit and counterparty risks, operational risk, and governance frameworks. We manage this complexity with precision.
CRR3 implementation for SA and IRB credit risk
End-to-end CRR3 implementation for both Standardised Approach (SA-CR) and IRB credit risk — data, methodology, parameter recalibration, system integration, parallel run, and supervisory approval. We deliver under the gradual 2025–2027 application calendar.
- SA-CR client classification & risk-weight redesign
- IRB PD / LGD / EAD recalibration under CRR3
- Parallel-run reconciliation & data quality remediation
- ECB / NCA technical dialogue and approval submission
RWA Optimisation (incl. Output Floor)
RWA optimisation across IRB, SA and the fully-loaded Output Floor. We surface the levers that recover capital before the floor bites — collateral recognition, CCF discipline, EAD granularity, exposure netting, securitisation tranching, defaulted-asset treatment.
- IRB optimisation: rating-grade granularity, downturn-LGD review
- SA-CR optimisation: collateral, CCF, due-diligence carve-outs
- Output-Floor strategy on a fully-loaded 72.5% basis
- CET1 lever inventory — quantified, sequenced, board-ready
EBA mandates (RTS / ITS / GL)
End-to-end response to EBA Level-2 and Level-3 mandates — Regulatory Technical Standards, Implementing Technical Standards, Guidelines. We track the pipeline, interpret the drafts, comment in consultation, and convert the final text into delivery work.
- RTS / ITS interpretation & gap analysis
- Consultation-paper response drafting
- Translation of Level-2 text into bank policy & methodology
- Implementation roadmap & supervisory submission
BCBS 239
Risk data aggregation and reporting principles. End-to-end compliance from data lineage to governance to IT infrastructure. We build the materiality, accuracy, completeness and timeliness controls that the JST and on-site inspectors actually test.
- Risk-data lineage end-to-end
- Data-quality controls & governance forum
- IT architecture for risk reporting
- Independent validation & remediation roadmap
FRTB / Market Risk
Fundamental Review of the Trading Book: Trading and Banking book boundaries, sensitivity-based approach, risk-factor definitions, model validation, desk-level RWA reporting. Full compliance with the CRR3 / BCBS 457 framework.
- TB / BB boundary definition & defence
- Risk-factor modelling & modellable / non-modellable split
- Desk segmentation & P&L attribution
- Model governance & regulatory reporting infrastructure
Model Risk Governance
Validation framework, model inventory, governance procedures, IT infrastructure. Support for IRB models, FRTB, CVA, and risk reporting models.
- Model inventory & taxonomy
- Validation framework design
- Control environment establishment
- Ongoing monitoring setup
Key Regulatory Tags
Eight pillars. One disciplined path from CRR3 gap to supervisory approval.
Most regulatory programmes drift between legal interpretation, IT delivery, and model validation. Ezelman imposes a single operating grammar — DELIVERY™ — that keeps CRO, CFO, Supervisory Liaison, and Programme Director aligned across 18-to-36 months.
Used on every Ezelman CRR3 and Basel IV mandate since 2022. Memorise it. Quote it. Defend it.
DIAGNOSE
Gap analysis CRR3 vs. current rulebook. Quantify RWA/CET1 impact by portfolio.
ENGAGE
Open supervisory dialogue early. Anchor interpretations before the JST locks a position.
LEAD
Board-level sponsorship. Translate regulatory mandate into strategic capital narrative.
IMPLEMENT
Taxonomy, methodology, data pipelines, calculation engines — built once, built right.
VALIDATE
Independent model validation + dual-run reconciliation. Kill surprises before supervisors find them.
EMBED
Embed within risk, finance, and IT teams. Knowledge transfer while we deliver.
REPORT
COREP / FINREP / Pillar 3 under the new taxonomy. Narrative, not just numbers.
YIELD
RWA optimisation and capital release post-transition. The reason the Board funded this.
Sitewide policy: every figure on ezelman.com is public-sourced, an estimate with stated methodology, or qualitative.
Our Approach
Regulatory implementation — whether CRR3, BCBS 239, an EBA mandate (RTS / ITS / GL), the Pillar 3 ESG framework or an ICAAP refresh — is never purely technical. It requires translation between business, risk, finance, IT and supervisory languages. We orchestrate this alignment for any regulation in scope.
Design Phase
We begin with strategic design workshops with your board, CRO, CFO and CDO. What does the regulation mean for your franchise? Where does it intersect with competitive strategy and capital allocation? Equally applicable to a CRR3 RWA bridge, a BCBS 239 lineage scope, or an EBA RTS interpretation.
- Gap analysis against the relevant regulation (CRR3, BCBS 239, an EBA mandate, ICAAP…)
- Regulatory impact quantification — capital, data, IT, governance
- Business case & competitive positioning
- High-level implementation roadmap with sequenced milestones
Build Phase
Technical implementation of frameworks, models, data lineage and reporting. We embed within your teams, transferring knowledge while maintaining delivery momentum — whether the build is a CRR3 SA-CR engine, a BCBS 239 data-lineage stack, or an EBA-mandate methodology document.
- Framework & taxonomy design
- Data infrastructure build & lineage controls
- Model development & validation (IRB, FRTB, CVA, ESG)
- System integration, parallel run & testing
Supervisory Engagement
We lead dialogue with ECB Banking Supervision, NCAs, and other regulators. Proactive clarification of interpretations, early signalling of design choices, management of feedback cycles — whether the regulator is reading a CRR3 application, an ICAAP, a BCBS 239 self-assessment or an EBA-mandate response.
- Supervisory strategy & messaging
- Technical documentation preparation
- Q&A management & escalation
- Approval / non-objection navigation
Transition & Optimisation
Managed transition to steady-state operations. Optimisation of RWA, capital, liquidity, data and reporting metrics within regulatory constraints. Continuous monitoring and supervisory adaptation — the work that converts a one-off implementation into a permanent capability.
- Parallel-run management & cutover
- System cutover, validation & back-reconciliation
- RWA, capital & data-quality optimisation
- Ongoing regulatory evolution — CRR3, BCBS 239, EBA mandates
Why Regulatory Programmes at Ezelman
Whatever the regulation in scope — CRR3, BCBS 239, an EBA mandate, an ICAAP refresh, or a Pillar 3 ESG build — implementation requires equal parts technical mastery and supervisory savvy. Our team brings both.
Deep regulatory expertise
Hands-on delivery across CRR3, Basel IV, BCBS 239, EBA mandates (RTS / ITS / GL), ICAAP / ILAAP and Pillar 3 disclosures. We do not interpret regulation in the abstract — we have built the methodology, run the parallel run, and defended the choice in front of a JST.
ECB & NCA relationships
Direct relationships with ECB Banking Supervision, NCAs across Europe, and major investment banks’ regulatory teams. We know how supervisors read a CRR3 application, a BCBS 239 self-assessment, or an EBA-mandate response — and what they are looking for first.
Proven track record
Multi-year engagements with several G-SIBs and Tier-1 banks on capital, data and governance transformation — CRR3 implementations in production, BCBS 239 remediation programmes, and EBA-mandate consultation responses delivered into supervisory dialogue.
Execution excellence
We do not leave the delivery to junior staff. Every major milestone is signed off by a founding team member — whether it is a CRR3 RWA bridge, a BCBS 239 lineage map, or an EBA RTS interpretation memo. You get accountability and experience on every deliverable.