Which Banks Are Basel III Compliant: G-SIBs and Pillar 3 Checks

There is no single global list of Basel III compliant banks, because Basel III is not enforced globally — it is enforced by each participating country’s own regulators against their local version of the rules. The closest thing to a named roster is the Financial Stability Board’s annual list of 29 Global Systemically Important Banks, which carry the strictest version of the requirements. Every other licensed bank in a participating country must also meet the framework, but at a level scaled to its size and risk. To confirm any specific bank’s status, you check its published capital and liquidity ratios against the minimums that apply to its category.

The 29 Global Systemically Important Banks

The Financial Stability Board (FSB) publishes an annual list of Global Systemically Important Banks (G-SIBs) — institutions whose failure could destabilize the international financial system. The FSB scores banks on size, interconnectedness, cross-border activity, and other risk factors, then assigns each to a “bucket” that sets how much extra Common Equity Tier 1 (CET1) capital the bank must hold above the standard minimums.1FSB.org. Global Systemically Important Financial Institutions

The 2025 list, based on end-of-2024 data, names 29 banks. The surcharges from this designation take effect on January 1, 2027.2FSB.org. 2025 List of Global Systemically Important Banks (G-SIBs)

  • Bucket 4 (2.50% surcharge): JP Morgan Chase
  • Bucket 3 (2.00%): Bank of America, Citigroup, HSBC, Industrial and Commercial Bank of China
  • Bucket 2 (1.50%): Agricultural Bank of China, Bank of China, Barclays, BNP Paribas, China Construction Bank, Goldman Sachs, Groupe Crédit Agricole, Mitsubishi UFJ FG, UBS
  • Bucket 1 (1.00%): Bank of Communications, Bank of New York Mellon, Deutsche Bank, Groupe BPCE, ING, Mizuho FG, Morgan Stanley, Royal Bank of Canada, Santander, Société Générale, Standard Chartered, State Street, Sumitomo Mitsui FG, Toronto Dominion, Wells Fargo

Bucket 5, which would carry a 3.50% surcharge, is empty. The framework keeps that top bucket empty on purpose: any bank that grows large enough to land in it faces a steep capital penalty for doing so.

Every Other Bank the Framework Touches

The G-SIB list is the top layer. Below it, individual countries designate their own Domestic Systemically Important Banks (D-SIBs), which face enhanced requirements within their home jurisdictions. Thousands of smaller banks still have to meet the core Basel III minimums as adopted by their regulators, though the exact requirements scale down with the bank’s size and risk profile.

In the United States, the Federal Reserve, OCC, and FDIC sort large banks into four categories under a 2019 tiered framework:3Federal Register. Changes to Applicability Thresholds for Regulatory Capital and Liquidity Requirements

  • Category I: U.S. G-SIBs. Every requirement applies: full Liquidity Coverage Ratio, Net Stable Funding Ratio, supplementary leverage ratio, countercyclical buffer, G-SIB surcharge, and annual stress testing.
  • Category II: Banks with $700 billion or more in total assets, or $75 billion or more in cross-border activity. Full LCR and most enhanced requirements.
  • Category III: Banks with $250 billion or more in assets, or $75 billion or more in short-term wholesale funding, nonbank assets, or off-balance-sheet exposure. Full or reduced LCR depending on wholesale funding.
  • Category IV: Banks with $100 billion to $250 billion in assets that don’t meet the higher category tests. Significantly lighter requirements, and no LCR obligation unless wholesale funding exceeds $50 billion.4Office of the Comptroller of the Currency. Applicability Thresholds for Regulatory Capital and Liquidity Requirements: Final Rule

Banks under $100 billion in assets fall outside this tiered framework entirely. They still meet basic risk-based capital and leverage requirements, but are exempt from the LCR, NSFR, and the most complex risk calculations. Community banks operate under a simplified capital framework built for their straightforward business models.

A bank that operates across borders complies with the rules of every jurisdiction where it is chartered or supervised. A European subsidiary of a U.S. bank follows EU rules for that entity; the parent follows U.S. rules at the consolidated level. Compliance is always measured against local law, not against the Basel Committee’s text itself.

What Compliance Actually Requires

Basel III rests on three pillars: capital adequacy, liquidity standards, and a leverage ratio. To call a bank compliant, you’re really asking whether it clears each of the relevant minimums.

Capital Ratios

Capital requirements set the minimum high-quality capital a bank must hold relative to risk-weighted assets (RWA). The three floors are:

  • Common Equity Tier 1 (CET1): at least 4.5% of RWA. The most loss-absorbing form of capital — mainly common stock and retained earnings.
  • Tier 1 Capital: at least 6.0% of RWA. Adds certain preferred shares to the CET1 base.
  • strong>Total Capital: at least 8.0% of RWA. Includes subordinated debt and other Tier 2 instruments.

On top of these, every bank must hold a Capital Conservation Buffer of 2.5% in CET1, raising the effective CET1 floor to 7.0%. National regulators can also switch on a Countercyclical Capital Buffer of up to 2.5% during periods of excessive credit growth, and G-SIBs carry their bucket surcharge on top of that. A G-SIB in Bucket 3, for example, needs a CET1 ratio of at least 9.0% (4.5% minimum plus 2.5% conservation buffer plus 2.0% surcharge).

Liquidity Ratios

The Liquidity Coverage Ratio (LCR) requires enough high-quality liquid assets to survive 30 days of severe funding stress. The minimum is 100%.5Bank for International Settlements. Basel III: The Liquidity Coverage Ratio and Liquidity Risk Monitoring Tools The Net Stable Funding Ratio (NSFR) requires stable funding sources over a one-year horizon, also at a 100% minimum.6Bank for International Settlements. Net Stable Funding Ratio Disclosure Standards

Leverage Ratio

The leverage ratio is a non-risk-weighted backstop: Tier 1 capital divided by total exposures, with a 3% minimum.7Bank for International Settlements. Basel III Leverage Ratio Framework and Disclosure Requirements G-SIBs face an enhanced version above the 3% floor.

In the United States, large banks also carry a Stress Capital Buffer (SCB) that replaces the fixed 2.5% conservation buffer. The SCB comes out of the Federal Reserve’s annual supervisory stress tests, with a 2.5% floor but often higher.8eCFR. 12 CFR 225.8 – Capital Planning and Stress Capital Buffer Requirement A bank that falls short of its total requirement faces automatic restrictions on dividends and bonus payments.9Federal Reserve Board. Federal Reserve Board Announces Final Individual Capital Requirements for Large Banks

How to Verify a Specific Bank

Basel III itself requires banks to publish their capital and risk data. This is called Pillar 3 disclosure, and it is the most direct way to check whether a bank clears its minimums.10Bank for International Settlements. Pillar 3 Disclosure Requirements – Regulatory Treatment of Accounting Provisions

Pillar 3 Reports

Most large banks publish Pillar 3 reports on their investor relations pages, alongside annual and quarterly financial statements. The reports include a standardized key metrics template (KM1) that shows the CET1 ratio, Tier 1 ratio, total capital ratio, leverage ratio, LCR, and NSFR, usually as a time series over recent quarters. Compare each reported ratio against the minimum that applies to the bank’s category, buffers included.

U.S. Regulatory Filings

U.S. bank holding companies file the FR Y-9C report with the Federal Reserve, which includes detailed capital calculations and risk-weighted asset breakdowns.11Federal Reserve Board. FR Y-9C Consolidated Financial Statements for Holding Companies Individual commercial banks file quarterly Call Reports (Reports of Condition and Income) with the FDIC. Both are public.

The easiest way in is the FFIEC Central Data Repository, which covers most FDIC-insured institutions with data back to 2001. You can search by institution name or FDIC certificate number and download reports in several formats.12FFIEC Central Data Repository. View or Download Data for Individual Institutions

Reading the Numbers

The interpretation is straightforward. If a bank reports a CET1 ratio of 12.5% and its total requirement (minimum plus buffers plus any surcharge) is 9.5%, it has a comfortable margin. An LCR of 115% means liquid assets exceed projected 30-day stress outflows by 15%. A leverage ratio of 6.2% against a 3% minimum is well above the backstop.

Look at three things: whether the bank clears its total requirement, how wide the margin is, and whether the trend over recent quarters is stable or declining. Most publicly traded banks run ratios well above their minimums, precisely because the consequences of getting close are severe.

What Falling Short Triggers

The first line of defense is the buffer framework. A bank that dips into its Capital Conservation Buffer (or SCB for large U.S. banks) faces automatic restrictions on dividends, share buybacks, and discretionary bonuses. The deeper the shortfall, the tighter the restrictions.13eCFR. 12 CFR Part 217 – Capital Adequacy of Bank Holding Companies

If capital falls below the regulatory minimums themselves, U.S. regulators apply Prompt Corrective Action (PCA). To be “well capitalized,” a bank needs a CET1 ratio of at least 6.5%, a Tier 1 ratio of at least 8.0%, a total capital ratio of at least 10.0%, and a leverage ratio of at least 5.0% — higher than the Basel III bare minimums.14eCFR. 12 CFR Part 6 – Prompt Corrective Action “Adequately capitalized” aligns with the Basel floors; anything below that is “undercapitalized.”

An undercapitalized bank must submit a capital restoration plan, and its ability to grow assets or open branches is restricted. A bank that is not well capitalized loses the ability to accept brokered deposits, an important funding source for many institutions,15FDIC.gov. Federal Deposit Insurance Act Section 29 – Brokered Deposits and cannot offer deposit rates significantly above prevailing market rates. In extreme cases, regulators can force the bank into receivership.

That is why a CET1 ratio of 12% or 13% against a 7% minimum isn’t excessive caution. It’s the management buffer that keeps a bank clear of the restriction zone through stress tests, downturns, and the reputational damage of getting close.