DK comments on the Delegated Act of the European Commission on the Implementation of FRTB

The German Banking Industry Committee (DK) comments on the draft delegated act regarding the European implementation of the new own funds requirements for market risk (Fundamental Review of the Trading Book – FRTB). Against the backdrop of significantly divergent implementation approaches across key international jurisdictions, the European Commission has exercised its mandate under Article 461a of the Capital Requirements Regulation (CRR) and postponed the application of the FRTB by two years until 2027.

For the start of application, the delegated act proposes targeted adjustments to the rules, which are limited to a period of three years. The DK welcomes these adjustments but continues to see a need for further clarification.

In particular, the FRTB also introduces new provisions regarding the boundary between the trading book and the banking book, which are not sufficiently addressed in the delegated act. In order to ensure legal certainty, timely communication of supervisory expectations for the coming years—especially by the European Banking Authority (EBA)—is therefore required.

DK comments market risks

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21.05.2026

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