Simplifying the Going Concern Stacking Orders of EU Banking Capital Rules:

A Review of the June 2026 Report of the European Banking Authority

On 7 September 2026, the above referenced Working Paper of Bart P.M. Joosen has been published in the EBI Working Paper Series 2026 – no. 213

The WP’s Abstract is:

“In the discourse surrounding the ‘simplification’ of capital requirements for EU banks, reference is often made to the assumption that the EU has deviated from the path delineated by the Basel Committee on Banking Supervision in the Basel III standards framework. The European Union, for example, has been accused of ‘gold-plating’ Basel III, and reversing this would enable a return to the original concepts in a proposed method for simplifying the capital requirements framework.

This contribution analyses whether the recommendations currently under consideration – as follows, amongst others, by the EBA’s report of June 2026 – effectively constitute a conceptual ‘reset’ of EU capital requirements back to the Basel Committee’s original standards. The present study hypothesises that there is a possibility that the current recommendations may amplify the friction with the original concepts set out in the Basel III standards. This does not imply that simplification – without relinquishing the absolute level of capital requirements – cannot be achieved via an alternative approach. This contribution explores a number of alternative ideas and makes further recommendations for corrections that should be made to have an impact on capital adequacy and proper use of buffers for the loss absorbing function which prevents the need to seek recourse to the minimum capital as required to be held by banks.”

The Paper can be downloaded via this link  and via https://papers.ssrn.com/sol3/papers.cfm?abstract_id=7429140.

In de course of the autumn 2026, this Working Paper will be followed up with a further study concerning the Gone Concern Stacking Orders of the EU Resolution framework.uropean Banking Authority

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