The tide of opinion among industry practitioners, academics and many regulators is turning ever more strongly in favour of greater proportionality. In this paper, we draw on insights from landmark studies in the European space, such as the EBA Banking Stakeholder Group’s 2016 report, and the European Banking Institute’s 2018 working paper. From the industry side, we also welcome the short position paper issued jointly by nine national banking associations in Europe. We agree, in general, with their analysis and conclusions. The Basel Committee itself is now waking up to the problem, with its recent publication of the results of a proportionality survey among national supervisors, and several papers from the Financial Stability Institute. And with the start of EU implementation of the “Basel 4” package now imminent, the time for action in the EU has arrived. 

An updated position paper from the cooperative and mutual banking associations of Germany, Austria, Italy, Spain, Poland, Luxembourg and the UK.