The ISDA and IIF respond to the PRA’s proposed adjustments to Basel 3.1, urging for enhanced risk sensitivity, operational practicality, and global consistency to ensure fair competition and financial stability amid complex regulatory reforms.

The joint response from the International Swaps and Derivatives Association (ISDA) and the Institute of International Finance (IIF) was submitted on September 12, 2025, addressing the Prudential Regulation Authority’s (PRA) consultation on proposed tweaks to the market risk capital framework under Basel 3.1. Their message emphasizes how crucial it is to have a risk-sensitive and harmonized market risk capital system across different jurisdictions, mainly to prevent competitive disadvantages caused by varying regulatory standards.

Both organizations back the PRA’s plan to push back the start date for implementing the Fundamental Review of the Trading Book (FRTB) internal models approach by a year — so, now, it’s set for January 2028. They argue this extra time can help iron out operational problems and the complex nature of the models. Still, they point out that managing a dual setup — where banks are expected to run both the new FRTB Standardized Approach (FRTB-SA) and their current Basel 2.5 internal models — is no small feat. To ease this burden, they suggest a mechanism that lets banks opt out either to stick with their existing internal models or switch fully to FRTB-SA by 2027. Such flexibility, they say, might help make the process smoother and better aligned with the PRA’s goal of rolling out Basel 3.1 efficiently.

In their reply, they also acknowledge the PRA’s plans to adjust how collective investment undertakings (like funds) and the residual risk add-on in the FRTB-SA are treated — considering these as steps in the right direction to address some implementation issues. Yet, ISDA and the IIF are advocating for further improvements to boost adoption, make the measures more risk-sensitive, and improve operational practicality. Beyond just this consultation, they reaffirm longstanding suggestions to reduce the framework’s overall complexity and encourage more widespread use of internal models, which they see as essential for proper risk calibration that keeps markets liquid and stable.

A bigger concern they raise deals with the inconsistencies in how Basel 3.1 is being adopted across different countries. They worry these discrepancies could distort competition on a global scale. So, they are calling on the Basel Committee on Banking Supervision to step up oversight over cross-border harmonization efforts, making sure divergent rules don’t interfere with fair competition or the integrity of the framework.

The PRA’s own consultation document hints at several operational simplifications — things like revising how collective investment schemes are treated in terms of boundaries and capital, setting up permissions for the residual risk add-on under the Advanced Standardised Approach (ASA), and updating reporting and disclosure standards. These suggestions aim to make implementing Basel 3.1 smoother for UK banks without losing sight of the core goals—risk sensitivity and financial stability.

This response from ISDA and IIF isn’t isolated; it fits into a broader industry conversation on Basel reforms. Past consultations, whether with the European Commission or US regulators, have underlined the need for a risk-appropriate approach and warning against market side effects. For instance, in January 2024, ISDA and SIFMA (the Securities Industry and Financial Markets Association) warned US authorities that overly strict capital rules could squeeze market liquidity and bump up the costs for financing.

The Basel 3.1 framework, initially endorsed by the Group of Central Bank Governors and Heads of Supervision in 2016, is meant to sharpen market risk standards by better defining the boundaries of banking and trading books, upgrading internal models, and making standardized approaches credible fallback options. The current phase of implementation, which the PRA’s consultation is part of, has proven quite intricate, with industry players seeking further nuanced adjustments to strike the right balance between prudence and practical operation.

In sum, the joint voice of ISDA and IIF appeals for a balanced, flexible, and internationally consistent rollout of Basel 3.1’s market risk rules. They advocate for pragmatic solutions that ease operational burdens, improve risk sensitivity, and help preserve market function and competitiveness. Honestly, this ongoing dialogue underscores just how complex and vital these reforms are for the future financial landscape.


References: - For the first paragraph: [[1]](https://www.isda.org/2025/09/12/isda-iif-respond-to-pra-on-adjustments-to-basel-3-1-market-risk-framework/), [[2]](https://www.isda.org/2025/09/12/isda-iif-respond-to-pra-on-adjustments-to-basel-3-1-market-risk-framework/), [[5]](https://www.isda.org/2025/04/22/isda-iif-response-to-ecs-consultation-on-the-market-risk-prudential-framework/) - Second paragraph: [[1]](https://www.isda.org/2025/09/12/isda-iif-respond-to-pra-on-adjustments-to-basel-3-1-market-risk-framework/), [[2]](https://www.isda.org/2025/09/12/isda-iif-respond-to-pra-on-adjustments-to-basel-3-1-market-risk-framework/), [[3]](https://www.bankofengland.co.uk/prudential-regulation/publication/2025/july/basel-3-1-adjustments-to-the-market-risk-framework-consultation-paper) - And onward for the other points, following the references.

It’s pretty interesting, right? I find it surprising that despite all these efforts, getting everyone on the same page—well, still a challenge.

Source: Noah Wire Services

Verification / Sources

  • https://www.isda.org/2025/09/12/isda-iif-respond-to-pra-on-adjustments-to-basel-3-1-market-risk-framework/ - Please view link - unable to able to access data
  • https://www.isda.org/2025/09/12/isda-iif-respond-to-pra-on-adjustments-to-basel-3-1-market-risk-framework/ - On September 12, 2025, the International Swaps and Derivatives Association (ISDA) and the Institute of International Finance (IIF) submitted a joint response to the Prudential Regulation Authority's (PRA) consultation on adjustments to the market risk capital framework (CP 17/25). The response emphasizes the need for a risk-appropriate and consistent market risk capital framework across jurisdictions to ensure a level playing field. While supporting the proposed delay to the Fundamental Review of the Trading Book (FRTB) internal models approach, the associations highlight operational challenges of maintaining dual systems and advocate for flexibility, including an opt-out mechanism for banks to continue with existing models or transition fully to the FRTB standardized approach by 2027. The response also addresses proposed changes to the treatment of collective investment undertakings and the residual risk add-on, suggesting further adjustments are necessary. Additionally, the response includes recommendations to achieve a more risk-sensitive FRTB, reduce operational complexity, and encourage wider adoption of internal models. The associations stress the importance of the Basel Committee thoroughly examining inconsistencies in implementation across jurisdictions.
  • https://www.bankofengland.co.uk/prudential-regulation/publication/2025/july/basel-3-1-adjustments-to-the-market-risk-framework-consultation-paper - In July 2025, the Bank of England published a consultation paper (CP17/25) proposing adjustments to the market risk framework under Basel 3.1. The consultation includes a one-year delay to the implementation of the Fundamental Review of the Trading Book (FRTB) internal models approach, moving the effective date to January 2028. The paper also proposes operational simplifications for the treatment of collective investment undertakings in the trading book boundary and the Advanced Standardised Approach (ASA), introduces a permissions regime to support the proportionate capitalisation of residual risks in the ASA, and updates reporting and disclosure obligations to align with these proposals. The consultation seeks feedback from stakeholders on these proposed adjustments.
  • https://www.isda.org/2023/03/31/isda-responds-to-pra-consultation-on-basel-3-1-implementation/ - On March 31, 2023, ISDA and the Association for Financial Markets in Europe (AFME) submitted a joint response to the UK Prudential Regulation Authority's (PRA) consultation on implementing the Basel 3.1 standards. The response emphasizes the necessity of implementing Basel 3.1 in a risk-sensitive manner to preserve financial stability and ensure a robust UK banking sector. It includes proposals for targeted revisions to various frameworks, including the output floor, credit risk, credit valuation adjustment risk, standardized approach for counterparty credit risk, market risk, and operational risk, aiming to improve risk sensitivity, reduce unnecessary burdens on firms, and ensure continued access to key financing, liquidity, and hedging services for corporates and other end users at reasonable costs.
  • https://www.isda.org/2025/04/22/isda-iif-response-to-ecs-consultation-on-the-market-risk-prudential-framework/ - On April 22, 2025, ISDA and the Institute of International Finance (IIF) submitted a joint response to the European Commission's consultation on the application of the market risk prudential framework. The associations advocate for a risk-appropriate and consistent capital framework across jurisdictions to ensure a level playing field and address concerns about divergent rules. They highlight the importance of resolving implementation issues within the Fundamental Review of the Trading Book (FRTB) framework and suggest that inconsistencies in regulatory implementation across jurisdictions should be addressed internationally under the Basel Committee on Banking Supervision.
  • https://www.isda.org/2024/01/16/isda-submits-responses-to-us-basel-iii-and-g-sib-surcharge-consultations/ - In January 2024, ISDA, in collaboration with the Securities Industry and Financial Markets Association (SIFMA), submitted a response to the US Basel III 'endgame' notice of proposed rulemaking (NPR). The response warns that proposed increases in capital for bank trading activities may not reflect underlying risks and could negatively impact the liquidity and vibrancy of US capital markets, leading to higher costs and reduced choices for US businesses. The associations propose calibration changes to ensure the rules are appropriate and risk-sensitive, aiming to avoid adverse consequences for US capital markets and the broader economy.
  • https://www.bis.org/press/p160111.htm - In January 2016, the Basel Committee on Banking Supervision's oversight body, the Group of Central Bank Governors and Heads of Supervision (GHOS), endorsed a new market risk framework as part of the Basel III reform package. The revised framework includes improvements such as a more clearly defined boundary between the banking and trading books to reduce arbitrage opportunities, a revised internal models approach for more coherent risk capture, an enhanced model approval process with prudent recognition of hedging and portfolio diversification, and a revised standardized approach serving as a credible fallback and floor to the model-based approach, facilitating more consistent and comparable reporting of market risk across banks and jurisdictions.

Noah Fact Check Pro

The draft above was created using the information available at the time the story first emerged. We've since applied our fact-checking process to the final narrative, based on the criteria listed below. The results are intended to help you assess the credibility of the piece and highlight any areas that may warrant further investigation.

Freshness check

Score: 9

Notes: The narrative is fresh, dated September 12, 2025. The earliest known publication date of a substantially similar content is April 22, 2025, when ISDA and IIF responded to the European Commission's consultation on the market risk prudential framework. (isda.org) The report is based on a press release, which typically warrants a high freshness score. No discrepancies in figures, dates, or quotes were found. The narrative includes updated data but does not recycle older material. No similar content appeared more than 7 days earlier. The report is timely and relevant.

Quotes check

Score: 10

Notes: No direct quotes are present in the narrative. The content is paraphrased from the original press release, indicating originality.

Source reliability

Score: 10

Notes: The narrative originates from reputable organisations: the International Swaps and Derivatives Association (ISDA) and the Institute of International Finance (IIF). Both are well-established entities in the financial sector, enhancing the credibility of the report.

Plausability check

Score: 10

Notes: The claims made in the narrative are plausible and align with known industry practices and regulatory developments. The report discusses the PRA's consultation on Basel 3.1 adjustments, including the delay of the FRTB internal model approach to January 2028, which is consistent with previous announcements. (slaughterandmay.com) The language and tone are appropriate for the subject matter and target audience.

Overall assessment

Veredict (FAIL, OPEN, PASS): PASS

Confidence (LOW, MEDIUM, HIGH): HIGH

Summary: The narrative is fresh, original, and sourced from reputable organisations. It presents plausible claims consistent with known industry developments, with no significant credibility risks identified.