Coverage: 2026 · Information to 16 February 2026

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TGB Annual Banking Outlook · 16 February 2026

Banks enter 2026 with strong capital and a steady global economy, but policy rates, Basel III timetables, reserve holdings and payment rails are pulling apart, and official bodies now name geopolitics and fragmentation among the main risks to the system.

The desk view

The IMF expects global growth of 3.3% in 2026, broadly the pace of 2025, and banks enter the year in good health: ECB-supervised banks reported a CET1 ratio of 16.10% and US banks a return on assets of 1.27% in the third quarter of 2025. The harder questions are structural. Policy rates have diverged, with the federal funds range at 3.50–3.75% against an ECB deposit rate of 2.00%. The final Basel III rules apply on different dates in different jurisdictions: the UK has delayed its rules and the EU its trading-book rules, citing uncertainty over, or delays in, implementation elsewhere, including in the United States. Gold, at 20% of global reserves at market prices, has overtaken the euro's 16%. Sanctions now reach third-country banks and a rouble-backed stablecoin. Our view is that 2026 will reward banks that plan for several regulatory and payment regimes at once rather than one global standard.

3.3%
IMF projection for global growth in 2026
3.50–3.75%
Federal funds target range, held on 28 January 2026
16.10%
Aggregate CET1 ratio of ECB-supervised banks, third quarter of 2025
29
Banks on the FSB's 2025 list of global systemically important banks

Overview: a steady economy, a fragmenting system

The IMF's January 2026 update projects global growth of 3.3% in 2026 and 3.2% in 2027, rates similar to its estimated 3.3% outturn for 2025. It expects global headline inflation to fall from an estimated 4.1% in 2025 to 3.8% in 2026 and 3.4% in 2027. The Fund says technology investment, fiscal and monetary support, accommodative financial conditions and private sector adaptability are offsetting trade policy shifts, and names a reassessment of technology expectations and an escalation of geopolitical tensions as the key downside risks. Trade remains the weak link: the IMF projects world trade volume growth to slow from 4.1% in 2025 to 2.6% in 2026 before recovering to 3.1% in 2027.

The trade backdrop has stabilised but not normalised. The US effective tariff rate assumed in the IMF projections is 18.5%, against 18.7% in October 2025, while the rate for the rest of the world is unchanged at 3.5%. A dispute between China and the United States over export controls on semiconductors and rare earth minerals was followed by a truce that reduced bilateral tariffs until November 2026 and paused export controls.

For banks, the more important change is in the financial system itself. The Bank of England's Financial Policy Committee (FPC) said in December 2025 that key sources of risk include geopolitical tensions, fragmentation of trade and financial markets, and pressures on sovereign debt markets. The European Banking Authority built its 2025 EU-wide stress test around a resurgence in geopolitical tensions and entrenched trade fragmentation, including higher tariffs. In February 2026 the ECB said the world economy has undergone profound structural shifts related to geopolitics and changes in the international financial system since its euro repo facility for central banks was introduced in 2020. When a macroprudential committee, an EU stress test and a central bank all use the word fragmentation, it has moved from scenario towards baseline.

IMF real GDP growth projections, January 2026, %

Economy2025 (estimate)20262027
World3.33.33.2
Advanced economies1.71.81.7
United States2.12.42.0
Euro area1.41.31.4
Japan1.10.70.6
United Kingdom1.41.31.5
Emerging market and developing economies4.44.24.1
China5.04.54.0
India (fiscal-year basis)7.36.46.4
Middle East and Central Asia3.73.94.0

Source: International Monetary Fund, World Economic Outlook Update, January 2026: Global Economy: Steady amid Divergent Forces, 19 January 2026.

Growth in the advanced economies is projected at 1.8% in 2026, less than half the 4.2% projected for emerging market and developing economies. Within the advanced group, the United States at 2.4% leads, while the euro area at 1.3% and Japan at 0.7% lag.

Monetary policy: an easing cycle in its late stage

Central banks enter 2026 at different points in the cycle. The Federal Open Market Committee (FOMC) cut the federal funds target range by 0.25 percentage point at each of its September, October and December 2025 meetings, taking it to 3.50–3.75%. That was 75bp of easing in total. In December the Committee also judged that reserve balances had declined to ample levels and said it would start buying shorter-term Treasury securities as needed. It held the range on 28 January 2026, with two members preferring a further cut of 0.25 percentage point. The median participant's December 2025 projection put the federal funds rate at 3.4% at the end of 2026 and 3.1% at the end of 2027, against a longer-run value of 3.0%. The same projections put median US growth at 2.3% in 2026, after 1.7% in 2025, and PCE inflation at 2.4% in 2026, after 2.9% in 2025. By January the Committee described economic activity as expanding at a solid pace, job gains as low and inflation as somewhat elevated. The December decision drew three dissents, one for a larger cut and two for no change.

The ECB has stood still. On 5 February 2026 its Governing Council kept the deposit facility, main refinancing and marginal lending rates at 2.00%, 2.15% and 2.40%. It said the outlook was still uncertain, owing particularly to global trade policy uncertainty and geopolitical tensions, and that it was not pre-committing to a particular rate path. It cited low unemployment, solid private sector balance sheets, the gradual rollout of public spending on defence and infrastructure and past rate cuts as supports for growth.

The Bank of England is closer to the end of its easing. At its meeting ending on 4 February 2026 the Monetary Policy Committee voted 5–4 to hold Bank Rate at 3.75%, with four members voting for a cut to 3.5%. The Committee said Bank Rate had been reduced by 150 basis points since August 2024 and was likely to be reduced further, but that judgements around further easing would become a closer call. UK CPI inflation had fallen from 3.8% in September to 3.4% in December 2025.

Japan is moving the other way. The Bank of Japan set its guideline for the uncollateralised overnight call rate at around 0.75% on 19 December 2025, and kept it there on 23 January 2026 by an 8–1 vote, with the dissenting member proposing around 1.0%. The Bank said uncertainties about the US economy and trade policy had declined. In China the People's Bank lowered the 7-day reverse repo rate from 1.50% to 1.40% on 8 May 2025. The one-year and over-five-year loan prime rates were cut by 10 basis points to 3.0% and 3.5% on 20 May 2025 and were still unchanged at the 22 December 2025 fixing. With the IMF projecting Chinese growth of 4.5% in 2026 after 5.0% in 2025, the direction of travel there remains towards support rather than restraint.

Policy settings of major central banks at the time of writing

Central bankPolicy rateLatest decisionEarlier move
Federal ReserveFederal funds target 3.50–3.75%Held, 28 January 2026 (two votes for a cut)Cut 0.25pp on 10 December 2025, after cuts on 17 September and 29 October 2025
European Central BankDeposit facility 2.00%Held, 5 February 2026Main refinancing 2.15%, marginal lending 2.40%
Bank of EnglandBank Rate 3.75%Held 5–4, meeting ending 4 February 2026150bp of cuts since August 2024
Bank of JapanCall rate around 0.75%Held 8–1, 23 January 2026Set at around 0.75% on 19 December 2025
People's Bank of ChinaOne-year LPR 3.0%Unchanged at the 22 December 2025 fixingCut 10bp on 20 May 2025

Source: Board of Governors of the Federal Reserve System, Federal Reserve issues FOMC statement (28 January 2026), 28 January 2026; Board of Governors of the Federal Reserve System, Federal Reserve issues FOMC statement (10 December 2025), 10 December 2025; Board of Governors of the Federal Reserve System, Federal Reserve issues FOMC statement (17 September 2025), 17 September 2025; Board of Governors of the Federal Reserve System, Federal Reserve issues FOMC statement (29 October 2025), 29 October 2025; European Central Bank, Monetary policy decisions (5 February 2026), 5 February 2026; Bank of England, Monetary Policy Summary and minutes of the MPC meeting ending on 4 February 2026, 5 February 2026; Bank of Japan, Statement on Monetary Policy (23 January 2026), 23 January 2026; Bank of Japan, Change in the Guideline for Money Market Operations (19 December 2025), 19 December 2025; People's Bank of China, Highlights of Monetary Policies in 2025, 10 February 2026; People's Bank of China, Highlights of Monetary Policies in the First Three Quarters of 2025, 17 December 2025.

The gap between US and euro area policy rates is 1.50 to 1.75 percentage points, depending on where in the US target range it is measured. For banks with balance sheets on both sides of the Atlantic, that gap shapes funding costs, hedging and the relative value of dollar and euro deposits.

Banks enter the year from strength

US banks closed the third quarter of 2025 with improving earnings. FDIC-insured institutions reported net income of $79.3 billion in the quarter, up $9.4 billion (13.5%) on the second quarter, and a return on assets of 1.27%. Return on assets was up from 1.13% in the second quarter and 1.09% a year earlier. The net interest margin rose 9 basis points to 3.34%, above the pre-pandemic average of 3.25%. Past-due and nonaccrual loans were unchanged at 1.49% of total loans, below the pre-pandemic average of 1.94%, while the net charge-off ratio of 0.61% was 13 basis points above its pre-pandemic average. Unrealised losses on securities fell $58.2 billion (14.7%) to $337.1 billion, the lowest since the first quarter of 2022.

The weak spots are specific. Banks with more than $250 billion of assets reported a non-owner-occupied commercial real estate past-due and nonaccrual rate of 4.18%, against a pre-pandemic average of 0.59%, although the rate has fallen for the fourth consecutive quarter from a peak of 4.99% in the third quarter of 2024. Loans to non-depository financial institutions and loans to purchase or carry securities had the largest dollar increase among loan categories, within total loan growth of $159.0 billion (1.2%) on the quarter. The FDIC said part of that increase reflected reclassifications in how certain loans are reported. The industry's annual rate of loan growth was 4.7%, still below the pre-pandemic average of 4.9%. The FDIC's Problem Bank List fell to 57 banks, 1.3% of the total. Even so, lending to non-bank financial institutions is one of the channels to watch, given the risks set out later in this outlook.

Euro area banks combine high capital with slightly softer returns. The aggregate CET1 ratio of banks supervised directly by the ECB was 16.10% in the third quarter of 2025, against 16.12% in the previous quarter and 15.73% a year earlier. Their annualised return on equity slipped to 9.88% from 10.11% in the previous quarter, and ranged from 6.82% in France to 16.66% in Lithuania. The non-performing loan ratio was unchanged at 2.22%, and the liquidity coverage ratio was 156.73%. Loans collateralised by commercial property had an NPL ratio of 4.58% and loans to small and medium-sized enterprises 4.88%. The ECB's November 2025 Financial Stability Review judged the sector resilient but warned that exposures to tariff-sensitive firms and closer funding ties with non-banks could strain banks in a downturn.

Stress tests in 2025 point the same way. The EBA's exercise covered 64 banks from 17 EU and EEA countries and 75% of EU banking assets. Under an adverse scenario of geopolitical tension and trade fragmentation, banks bore losses of EUR 547bn, and capital depletion of 370 bps left a CET1 ratio of 12% at the end of the horizon. In the Bank of England's 2025 test, the aggregate CET1 ratio of UK banks started at 14.5% and fell to a low point of 11.0% in the first year, and no bank had to strengthen its capital. That is a drawdown of 3.5 percentage points.

Bank resilience indicators, latest available data

SystemCapital and liquidityEarningsAsset qualityPeriod
United States, FDIC-insured banksUnrealised securities losses $337.1bnROA 1.27%; net interest margin 3.34%Past-due and nonaccrual 1.49%; net charge-offs 0.61%Q3 2025
Euro area, ECB-supervised banksCET1 16.10%; LCR 156.73%RoE 9.88%NPL ratio 2.22%Q3 2025
UK banks, Bank Capital Stress TestCET1 14.5% at start, 11.0% at low pointNot reportedNo bank required to strengthen capital2025 stress test
EU banks, EBA stress test370bp CET1 depletion, 12% at end of scenarioNot reportedLosses of EUR 547bn under the adverse scenario2025 stress test

Source: Federal Deposit Insurance Corporation, FDIC Quarterly Banking Profile Third Quarter 2025 (statement), 24 November 2025; Federal Deposit Insurance Corporation, FDIC-Insured Institutions Reported Return on Assets of 1.27 Percent and Net Income of $79.3 Billion in Third Quarter 2025 (press release), 24 November 2025; European Central Bank (Banking Supervision), ECB publishes supervisory banking statistics on significant institutions for the third quarter of 2025, 17 December 2025; Bank of England, Financial Stability Report - December 2025, 2 December 2025; European Banking Authority, The EBA publishes the results of its 2025 EU-wide stress test, 1 August 2025.

Capital: one Basel standard, several timetables

The Basel Committee said in November 2025 that full and consistent implementation of Basel III remains its highest priority. In practice the final reforms are arriving on different dates. Japan applied the finalised framework, including the 2019 market risk standard, to internationally active banks and internal-model users from 31 March 2024, and scheduled the remaining institutions for 31 March 2025. Switzerland set 1 January 2025 for its implementing ordinances, and FINMA later said the final Basel III standardised approach for market risks had been available since that date. In the EU most Basel III requirements entered into force on the same date.

The trading-book rules are where timetables have split. On 12 June 2025 the European Commission postponed the EU application of the Fundamental Review of the Trading Book (FRTB) by a further year, to 1 January 2027. It said international developments pointed to further delays in Basel III implementation by some major jurisdictions, and that its concerns about the international level playing field remained high. In November 2025 it consulted on options to mitigate negative FRTB capital effects for EU banks for three years, ending in 2029, and said its postponement was justified by delays or deviations in other major jurisdictions.

The UK took a similar path. In January 2025 the Prudential Regulation Authority delayed Basel 3.1 by one year to 1 January 2027, to allow more time for clarity on US implementation plans. Its final rules, published on 20 January 2026, take effect on 1 January 2027, with the internal model approach for market risk following on 1 January 2028. Full implementation remains set for 1 January 2030.

In the United States the large-bank framework is being rebuilt. In December 2025 the Federal Reserve's Vice Chair for Supervision told Congress that the Board was considering changes to each of the four pillars of its capital framework for large banks: stress testing, the supplementary leverage ratio, the Basel III framework and the G-SIB surcharge. The testimony described finalising Basel III as an important act of closure for the sector that would reduce uncertainty about capital requirements. The agencies finalised changes to the enhanced supplementary leverage ratio on 25 November 2025, capping the enhanced standard for depository institution subsidiaries at 1% so that their overall requirement is no more than 4%. They estimated that the rule reduces tier 1 capital requirements for affected holding companies by less than 2% in aggregate, and it takes effect on 1 April 2026. Its stated aim is to reduce disincentives to low-risk activities such as intermediating in US Treasury markets.

Stress testing is also in transition. On 4 February 2026 the Federal Reserve Board voted to keep current stress capital buffer requirements until 2027, when new requirements can be calculated with models that take public feedback into account. The 2026 scenario takes the unemployment rate to a peak of 10%, with about a 30% fall in house prices and a 39% fall in commercial real estate prices, and 32 banks will be tested. The Board estimated that its proposed model and scenario changes would not materially change capital requirements in aggregate.

Final Basel III reforms: implementation by jurisdiction

JurisdictionMain application dateTrading book and transitionStatus at the time of writing
Japan31 March 2024 for internationally active banks and internal-model usersIncludes the 2019 market risk standard; remaining institutions scheduled for 31 March 2025In force for internationally active banks
Switzerland1 January 2025Standardised approach for market risks available since 1 January 2025In force
European Union1 January 2025 for most requirementsFRTB postponed to 1 January 2027; consultation on relief ending in 2029Partly in force
United Kingdom1 January 2027Market-risk internal models 1 January 2028; full implementation 1 January 2030Final rules published
United StatesNot finalisedEnhanced supplementary leverage ratio changes effective 1 April 2026Board considering changes to all four capital pillars

Source: Financial Services Agency of Japan, FSA Weekly Review No.582: Publication of a list of financial institutions implementing the finalized Basel III framework from March 31, 2024, 11 April 2024; Swiss Financial Market Supervisory Authority (FINMA), FINMA publishes ordinances to implement the final Basel III standards (press release), 27 March 2024; Swiss Financial Market Supervisory Authority (FINMA), FINMA launches consultations on the ordinances concerning risk diversification and liquidity for banks and securities firms (press release), 3 July 2025; European Commission, Commission proposes to postpone by one additional year the market risk prudential requirements under Basel III (press release), 12 June 2025; European Commission, Commission seeks input on Basel III market risk rules for banks (news article), 6 November 2025; Bank of England (Prudential Regulation Authority), PS1/26 - Implementation of the Basel 3.1 final rules (policy statement), 20 January 2026; Bank of England (Prudential Regulation Authority), The PRA announces a delay to the implementation of Basel 3.1, 17 January 2025; Board of Governors of the Federal Reserve System, Statement by the Vice Chair for Supervision before the Committee on Financial Services, US House of Representatives (2 December 2025), 2 December 2025; Board of Governors of the Federal Reserve System, FDIC and OCC, Agencies issue final rule to modify certain regulatory capital standards, 25 November 2025.

The UK has also revisited the overall level of capital. In December 2025 it lowered its benchmark for system-wide Tier 1 capital requirements to around 13% of risk-weighted assets, equivalent to a CET1 ratio of around 11%, from around 14%. It kept the UK countercyclical capital buffer at its neutral rate of 2%. The ECB, by contrast, said in November 2025 that macroprudential authorities should maintain existing capital buffer requirements. The IMF's October 2025 report said implementation of Basel III is paramount in times of high uncertainty and that efficiency reviews should not undermine the resilience of the banking sector or international minimum standards. Our reading is that capital is not falling sharply anywhere, but its composition and calibration are diverging. A bank operating in the EU, UK and US faces three sets of trading-book rules, and both the EU and the UK have cited delays or uncertainty elsewhere, including in the United States, as reasons for their timing. That raises the cost of capital planning even where headline ratios barely move. The G-SIB list adds a further layer. The Financial Stability Board's 2025 list includes the same 29 banks as in 2024, with a different allocation to buckets. Bank of America and Industrial and Commercial Bank of China moved up from bucket 2 to bucket 3, and Deutsche Bank moved down to bucket 1. The new bucket assignments determine the higher capital buffers that apply from 1 January 2027.

G-SIBs by bucket, FSB 2025 list (additional CET1 buffer applying in 2027)

BucketBanks
5 (3.5%)None
4 (2.5%)JP Morgan Chase
3 (2.0%)Bank of America, Citigroup, HSBC, Industrial and Commercial Bank of China
2 (1.5%)Agricultural Bank of China, Bank of China, Barclays, BNP Paribas, China Construction Bank, Goldman Sachs, Groupe Crédit Agricole, Mitsubishi UFJ FG, UBS
1 (1.0%)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

Source: Financial Stability Board, 2025 List of Global Systemically Important Banks (G-SIBs), 27 November 2025.

The geopolitics of finance: reserves, payment rails and sanctions

Reserve managers are diversifying, not least into gold. According to the ECB, the US dollar's share of global official foreign exchange reserves fell by 2.0 percentage points at constant exchange rates in 2024, to 57.8%, while the euro's share was stable at 20%. The renminbi's share was 2.2%, 0.4 percentage points below its 2022 peak. Central banks bought more than 1,000 tonnes of gold in 2024, double the average of the previous decade. At market prices gold's share of global reserves, at 20%, surpassed the euro's 16%, and survey data suggest two-fifths of central banks bought gold as protection against geopolitical risk. Surveys also suggest that 80% of reserve managers consider geopolitics a major factor for their portfolios over the next five to ten years.

The dollar has also weakened. The IMF said in October 2025 that the US dollar had depreciated by 10% so far that year, decoupling from wide US–G10 interest rate differentials. Alternative payment rails are also growing: transactions through China's Cross-Border Interbank Payment System rose by 22% to around USD 6 trillion in the fourth quarter of 2024. The FSB said in October 2025 that satisfactory global improvements in cross-border payments are unlikely to be achieved in line with the G20's 2027 timetable.

Central banks are building their own backstops. On 14 February 2026 the ECB announced an enhanced repo facility for central banks (EUREP), which gives all central banks standing access in principle unless excluded on grounds including money laundering, terrorist financing or international sanctions. It said that, in the context of greater fragmentation and uncertainty, facilities like EUREP would continue to provide backstop funding for central banks. The changes apply from the third quarter of 2026. The People's Bank of China and the ECB renewed their RMB350 billion (EUR45 billion) bilateral swap agreement on 7 September 2025. The IMF said that sufficient reserve buffers and an expanded network of central bank swap lines could help mitigate foreign exchange market volatility. Access to dollar, euro and renminbi liquidity in a stress is becoming part of the geopolitical map.

Sanctions have moved deeper into banking and payments. On 22 October 2025 the US Treasury sanctioned Rosneft and Lukoil, Russia's two largest oil companies, and warned that foreign financial institutions engaging in certain transactions involving them may risk secondary sanctions. The next day the EU adopted its 19th package, which added 5 Russian banks to its transaction ban and imposed transaction bans on 5 third-country banks in Central Asia. It banned Russia's Mir card and SBP fast payment system, and sanctioned the developer and issuer of the rouble-backed stablecoin A7A5 while prohibiting use of that token. The same package bans imports of Russian liquefied natural gas from 1 January 2027 under long-term contracts. For internationally active banks, sanctions compliance now extends to third-country correspondents, national payment schemes and crypto-assets.

Official measures reshaping cross-border finance

DateAuthorityMeasure
18 July 2025United StatesGENIUS Act signed, providing for the regulation of payment stablecoins
22 October 2025US Treasury (OFAC)Rosneft and Lukoil sanctioned; secondary-sanctions risk for foreign financial institutions
23 October 2025European Union19th package: 5 Russian and 5 Central Asian banks under transaction bans; Mir, SBP and A7A5 targeted
30 October 2025ECBDigital euro moves to next phase; first issuance possible during 2029
19 November 2025Basel CommitteeExpedited review of the bank cryptoasset standard
16 December 2025FDICProposed GENIUS Act application rules for bank subsidiaries
14 February 2026ECBEUREP standing access for all central banks, subject to exclusions

Source: The White House, The President Signed into Law S. 1582 (GENIUS Act), 18 July 2025; US Department of the Treasury, Treasury Sanctions Major Russian Oil Companies, Calls on Moscow to Immediately Agree to Ceasefire, 22 October 2025; European Commission, EU adopts 19th package of sanctions against Russia, 23 October 2025; European Central Bank, Eurosystem moving to next phase of digital euro project (press release), 30 October 2025; Basel Committee on Banking Supervision (BIS), Basel Committee continues to prioritise Basel III implementation, approves final principles on third-party risks and agrees to expedite targeted review of cryptoasset standard, 19 November 2025; Federal Deposit Insurance Corporation, FDIC Approves Proposal to Establish GENIUS Act Application Procedures for FDIC-Supervised Institutions Seeking to Issue Payment Stablecoins, 16 December 2025; European Central Bank, ECB enhances repo facility for central banks (press release), 14 February 2026.

Stablecoins and digital money: competing models

Private digital money has become a policy battleground. At the end of 2024 US dollar-based stablecoins accounted for around 99% of a stablecoin market capitalisation of about USD 190 billion, according to the ECB. The United States enacted the GENIUS Act on 18 July 2025 to regulate payment stablecoins. The FDIC said the Act allows insured depository institutions to issue payment stablecoins through a subsidiary, and on 16 December 2025 its Board proposed the application process. In the UK the Bank of England and the FCA are developing regimes for systemic and non-systemic stablecoins.

Official assessments remain cautious. The BIS said in June 2025 that stablecoins fall short as sound money and, without regulation, pose a risk to financial stability and monetary sovereignty. It argued that they do not deliver singleness of money, elasticity or integrity. The IMF's October 2025 report said stablecoins led by dollar-pegged coins are growing rapidly, with risks of currency substitution in weaker economies, changes in bond market structure and runs that force sales of reserve assets. The Basel Committee agreed in November 2025 to expedite a review of targeted elements of its standard for banks' cryptoasset exposures.

Europe's answer is public. On 30 October 2025 the ECB moved the digital euro into its next phase; if legislation is adopted in the course of 2026, a pilot could start in mid-2027 and the Eurosystem should be ready for a first issuance during 2029. The ECB said a digital euro would protect Europe's monetary sovereignty and economic security. The contrast between a US model built on regulated private issuers and a European model built on a central bank instrument is itself a form of fragmentation, and banks will need products and controls for both.

Risks for 2026: non-banks, valuations and sovereigns

A growing share of the risks that matter for banks sits outside them. The FSB reported that non-bank financial intermediation grew 9.4% in 2024, double the pace of the banking sector, lifting its share of global financial assets to 51% ($256.8 trillion). It highlighted severe limitations in the regulatory data available on private credit, a market the FSB Chair's letter to G20 Leaders put at an estimated US$2 trillion globally. The IMF's global stress test found that about 18% of global banks by assets would see their CET1 ratio fall below 7% plus any G-SIB buffer in an adverse scenario, and that additional shocks to non-banks would raise the share to 21%. The non-bank channel adds 3 percentage points to the weak-bank share.

Credit events in 2025 tested that link. The IMF said the defaults of Tricolor Holdings and First Brands exposed opaque financing structures, weak governance and lax underwriting, issues that have become more common with the growth of non-bank lenders, especially private credit. The FPC said two high-profile US corporate defaults had intensified focus on high leverage, weak underwriting, opacity, complex structures and reliance on credit rating agencies, and the Bank of England plans a system-wide exploratory scenario focused on private markets. The Basel Committee has also discussed banks' use of synthetic risk transfers, a market it said has grown rapidly over the past decade. The Committee said macroeconomic and geopolitical uncertainty, developments in credit and funding markets and operational risks remain key areas of focus for many supervisors. The IMF estimates that in a scenario of higher tariffs and refinancing costs the share of corporate debt with interest coverage below 1 would reach 55% in some countries.

Valuations are the second risk. The FPC said US equity valuations are close to their most stretched since the dot-com bubble, and UK valuations the most stretched since the global financial crisis. It cited industry estimates that AI infrastructure spending could exceed five trillion US dollars over five years, with about half expected to be financed externally, mostly through debt. The IMF's January update refers back to an October 2025 scenario in which a moderate correction in AI stock valuations, as part of a general tightening of financial conditions, reduces global growth by 0.4% in 2026 relative to baseline. In gilt markets, hedge funds' leveraged repo borrowing reached close to £100 billion in November 2025, with a small number of funds accounting for more than 90% of net borrowing.

Sovereign debt is the third. The IMF projects global sovereign debt to exceed 100% of GDP by the end of the decade, and flags elevated public debt in economies whose currencies and securities are systemically important. It warns that reliance on price-sensitive investors such as money market funds and leveraged hedge funds heightens dislocation risks and may require repeated central bank liquidity backstops. Its October report estimated that forced US Treasury sales by bond funds after large outflows could reach almost $300 billion in a scenario of an abrupt rise in yields. The ECB sees defence-related fiscal expansion and structural challenges as medium-term strains on euro area sovereigns. Operational risk completes the picture: the FPC said elevated geopolitical tensions increase the likelihood of cyberattacks.

Outlook: what this means for banks

We see three implications for 2026. First, capital planning becomes a multi-jurisdiction exercise: the EU trading-book rules and UK Basel 3.1 start on 1 January 2027, current US stress capital buffers are maintained until 2027, and US Basel III rules remain under review. Second, European policy rates are near the end of their cycle: the ECB is on hold at 2.00% and the Bank of England's Committee says further cuts are likely but will become a closer call, so margin support will depend more on volumes and fees than on rate moves. Third, geopolitical exposure has become a balance-sheet question as well as a compliance one, through sanctions on third-country banks, the reach of non-bank lending and the choice of reserve and settlement assets.

The supervisory message is consistent across the main authorities. The Basel Committee keeps Basel III implementation as its top priority, the ECB wants buffers maintained, and the IMF warns against eroding minimum standards, even as the UK lowers its capital benchmark and the US revisits its framework. The FSB Chair's letter noted that the FSB's interim implementation review found significant gaps in the implementation of financial reforms. We expect that tension between national competitiveness and global consistency to define the regulatory year.

What to watch

  • 19 March 2026: the Bank of England publishes the minutes of its MPC meeting ending on 18 March.
  • 1 April 2026: the US enhanced supplementary leverage ratio changes take effect; banks may adopt them from 1 January 2026.
  • Third quarter of 2026: the ECB's enhanced EUREP framework, with standing access for central banks, applies.
  • November 2026: the China–US truce on bilateral tariffs runs until this month, and the FSB publishes its next G-SIB list.
  • 1 January 2027: UK Basel 3.1 and the EU FRTB take effect, and the 2025 G-SIB bucket buffers apply.
  • During 2026: the ECB's working assumption is that EU co-legislators adopt the digital euro regulation, which would allow a pilot from mid-2027.

Primary sources: International Monetary Fund, World Economic Outlook Update, January 2026: Global Economy: Steady amid Divergent Forces, 19 January 2026; European Central Bank (Banking Supervision), ECB publishes supervisory banking statistics on significant institutions for the third quarter of 2025, 17 December 2025; Bank of England, Financial Stability Report - December 2025, 2 December 2025; European Commission, Commission proposes to postpone by one additional year the market risk prudential requirements under Basel III (press release), 12 June 2025; Bank of England (Prudential Regulation Authority), The PRA announces a delay to the implementation of Basel 3.1, 17 January 2025; European Central Bank, The international role of the euro, June 2025, 5 June 2025; European Central Bank, ECB enhances repo facility for central banks (press release), 14 February 2026; Federal Deposit Insurance Corporation, FDIC-Insured Institutions Reported Return on Assets of 1.27 Percent and Net Income of $79.3 Billion in Third Quarter 2025 (press release), 24 November 2025; 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Cover illustration: AI-generated