巴塞尔框架实施情况调查报告（英文版）_16页_863kb

Summary of the Survey Report on the Implementation of the Basel Framework

Introduction

Since the 2007-08 global financial crisis, international standard-setting bodies have introduced global standards to guide national regulators in designing and implementing frameworks that ensure financial stability. However, these standards are often seen as a challenge for developing countries, as they may restrict innovation and the adoption of new financial products and services that could enhance financial inclusion. In response, the G20 Principles for Innovative Financial Inclusion were developed, with the eighth principle emphasizing proportionality in regulatory frameworks to balance financial inclusion, integrity, and stability. The AFI Global Standards Proportionality Working Group (GSPWG) conducted a survey to understand how AFI member institutions are implementing the Basel framework, including proportionality, and the challenges they face.

About the Survey

The survey was distributed to members of the GSPWG in October 2017 and to the broader AFI network in May and June 2018. It aimed to provide insights into the current implementation of the Basel framework in AFI member jurisdictions. The survey included 13 questions across four areas: (i) broad implementation of the Basel framework; (ii) measuring the impact of Basel on financial inclusion; (iii) mitigating the impact of Basel on financial inclusion through proportionality; and (iv) challenges of implementing proportionality in the Basel framework. Responses were received from 39 jurisdictions, with a regional distribution as follows:

• 14 countries from Sub-Saharan Africa
• 7 from Latin America & Caribbean
• 4 from East Asia and Southeast Asia
• 4 from Europe & Central Asia
• 4 from the Middle East & North Africa
• 3 from the Pacific
• 3 from South Asia

Key Findings

Broad Implementation of the Basel Framework

• Basel I: All respondents have implemented the Basel I framework. 74% have adopted it fully, while 26% have adopted it partially. Some jurisdictions are still implementing market risk components under Basel II.
• Basel II: Over 80% of respondents have implemented the Basel II framework. 45% have adopted it fully, while 37% have adopted it partially. Pillar 1 (minimum capital requirements) is widely implemented, while Pillar 3 (market discipline) is less so. Some countries are still in pilot phases due to regulatory delays or market structure challenges.
• Basel III: About 68% of respondents have implemented the Basel III framework. 14% have fully adopted it, 54% have partially adopted it, and 32% have no short-term plans. Implementation has mainly focused on capital requirements and liquidity coverage ratio (LCR), with fewer adopting the net stable funding ratio (NSFR). Some countries have implemented aspects like leverage ratio and capital conservation buffer.

Measuring the Impact of Basel on Financial Inclusion

• 73% of respondents do not have a formal mechanism to measure the impact of Basel standards on financial inclusion.
• 24% believe the Basel standards have not had an impact on financial inclusion.
• 3% think the standards have negatively impacted financial inclusion, citing more expensive financial services, fewer services, and higher client onboarding costs.
• Some institutions noted that existing capital and liquidity levels were already above Basel minimums, so the reforms did not negatively affect financial inclusion. Others pointed to the potential for agent banking and digitization to support inclusion despite the standards.

Mitigating the Impact of Basel on Financial Inclusion through Proportionality

• 52% of respondents have adopted new credit categories with lower capital and liquidity requirements to support financial inclusion.
• 27% have implemented a tiered approach to Basel pillars, with some examples including differentiated requirements for domestic systemically important banks (D-SIBs) and smaller institutions.
• 27% have adopted the internal ratings-based (IRB) approach to justify lower capital requirements for lower-risk activities.
• 14% have adopted other proportionate approaches, such as differentiated regulations based on bank size and type.

Challenges of Implementing Proportionality

• Many jurisdictions face challenges in implementing proportionality, including lack of capacity and resources.
• Some institutions have not yet evaluated their proportionality approaches, indicating a need for further development and assessment.
• The complexity of the Basel framework, particularly in areas like market risk and operational risk, poses implementation difficulties, especially in smaller or less developed financial systems.

Conclusion

The survey highlights the widespread adoption of the Basel framework across AFI member institutions, with varying degrees of implementation. While proportionality is increasingly recognized as a key tool to balance financial inclusion with stability and integrity, its application remains uneven. Challenges such as limited resources, regulatory complexity, and the need for further evaluation persist. The report underscores the importance of continued peer learning and the development of proportionate approaches to ensure that global standards do not hinder financial inclusion in developing countries.