The Basel Committee on Banking Supervision has settled one question about how the world's largest banks are ranked for systemic importance and left another open. Window dressing is addressed in a final document. The treatment of cross-border exposures inside the European Banking Union is still a consultation, with comments due on January 14, 2027. The Financial Services Agency relayed both items on October 23, 2026.
What is final
The Committee published the final document, titled "Global systemically important banks - revised assessment framework to address window dressing", on October 16, 2026, according to the FSA. It partly revises the G-SIB assessment provisions of the Consolidated Basel Framework, which the Committee published in December 2019. It follows a public consultation that began in March 2024.
The FSA describes window dressing as regulatory arbitrage: some banks temporarily adjust positions around the reporting and disclosure reference dates for the data used to select G-SIBs, in an attempt to lower their assessed systemic importance. To curb this, most of the indicators used in G-SIB selection will be measured as averages over the full year.
What is still open
Separately, the Committee issued a consultation paper, "Global systemically important banks - methodology review". It asks whether the framework should incorporate the treatment of cross-border exposures within the European Banking Union that the Committee agreed in 2022.
Comments go to the Committee in English by Thursday, January 14, 2027. Unlike the averaging change, this question has no decision attached to it.
Gaps for Japanese banks
The FSA notice does not state an effective date for the full-year averaging or any Japanese implementing rule. It also gives no estimate of the effect on any bank's capital or G-SIB standing.