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Precise risk modelling for optimal capital efficiency

CRR Model

CRR modelling forms the analytical core of modern bank management and connects regulatory compliance with strategic capital optimisation. Our expertise in risk modelling, RWA calculation and model validation enables institutions not only to meet Basel III requirements, but to use them as a competitive advantage.

  • ✓Precise RWA modelling for optimal capital allocation
  • ✓Validated internal models for regulatory recognition
  • ✓Integrated stress testing frameworks for crisis resilience
  • ✓Automated model monitoring and performance tracking

Your strategic success starts here

Our clients trust our expertise in digital transformation, compliance, and risk management

30 Minutes • Non-binding • Immediately available

For optimal preparation of your strategy session:

  • Your strategic goals and objectives
  • Desired business outcomes and ROI
  • Steps already taken

Or contact us directly:

info@advisori.de+49 69 913 113-01

Certifications, Partners and more...

ISO 9001 CertifiedISO 27001 CertifiedISO 14001 CertifiedBeyondTrust PartnerBVMW Bundesverband MitgliedMitigant PartnerGoogle PartnerTop 100 InnovatorMicrosoft AzureAmazon Web Services

What requirements apply to internal models and the IRB approach under CRR?

Why ADVISORI for CRR model advisory?

  • Proven experience in IRB approval with audit-proof documentation
  • Quantitative modelling competence for PD, LGD, EAD, and market risk models
  • Deep understanding of CRR III changes including output floor, input floors, and FRTB
  • End-to-end approach: from portfolio analysis through model development to supervisory approval
⚠

Output Floor from 2025

Since January 2025, IRBA banks must comply with the output floor: internal RWA may not fall below 50% of SA-calculated RWA, rising to 72.5% by 2030. A parallel SA calculation is mandatory.

ADVISORI in Numbers

11+

Years of Experience

120+

Employees

520+

Projects

We combine regulatory expertise with quantitative modelling competence to develop internal models that achieve both supervisory approval and economic optimisation.

Our Approach:

Portfolio analysis and economic assessment: IRBA vs. SA per exposure class under output floor conditions

Development and calibration of PD, LGD, and EAD models per Art. 143-191 CRR

Independent model validation with discriminatory power, calibration, and stability tests

Preparation and support for supervisory approval with audit-proof documentation

FRTB implementation: trading desk analysis, PLA test, and IMA strategy development

"Precise CRR modelling is the key to intelligent capital management and sustainable competitiveness. Our experience shows that institutions with scientifically sound, regulatorily recognised models not only achieve better compliance outcomes, but also realise significant efficiency gains and strategic advantages."
Melanie Düring

Melanie Düring

Head of Risk Management

Our Services

We offer you tailored solutions for your digital transformation

RWA Model Development and Credit Risk Modelling

We develop precise RWA models for all credit risk categories and implement advanced approaches to optimise capital requirements under Basel III.

  • Development of PD, LGD and EAD models for all portfolio segments
  • Implementation of advanced IRB approaches and standardised approach optimisation
  • Calibration and validation of risk parameters using solid statistical methods
  • Development of portfolio models and correlation structures

Market Risk and Operational Risk Modelling

We implement comprehensive models for market risk and operational risk that fulfil regulatory requirements and enable strategic risk management.

  • Value-at-Risk models and Expected Shortfall calculations for market risk
  • Development of AMA models for operational risk
  • Implementation of stress testing frameworks for all risk types
  • Integration of climate risk and ESG factors into risk models

Model Validation and Regulatory Recognition

We conduct comprehensive model validations and accompany the entire process of regulatory recognition for internal models.

  • Independent model validation in accordance with regulatory standards
  • Backtesting and out-of-sample testing for model performance assessment
  • Preparation of regulatory documentation and application documents
  • Support throughout the approval process and supervisory dialogue

Stress Testing and Scenario Analysis

We develop solid stress testing frameworks that fulfil regulatory requirements and provide strategic planning support.

  • Development of ICAAP- and ILAAP-compliant stress testing models
  • Implementation of EBA stress tests and supervisory scenarios
  • Reverse stress testing and identification of critical thresholds
  • Integration of stress testing into strategic capital and business planning

Model Risk Management and Governance

We implement comprehensive model risk management frameworks and establish solid governance structures for sustainable model quality.

  • Building model risk management frameworks and governance structures
  • Implementation of model monitoring and continuous validation
  • Development of model inventories and risk assessment processes
  • Training and competency development for internal model risk management teams

Technology Integration and Automation

We implement modern technology solutions for efficient modelling, automated calculations and integrated risk management.

  • Implementation of modern modelling and calculation platforms
  • Automation of model calculations and validation processes
  • Integration of machine learning and AI into risk models
  • Development of real-time monitoring and alert systems

Our Competencies in CRR/CRD - Capital Requirements Regulation & Directive

Choose the area that fits your requirements

CRD Advanced Approach

The Advanced IRB Approach (A-IRB) allows institutions to estimate all risk parameters internally — probability of default (PD), loss given default (LGD), exposure at default (EAD) and credit conversion factors (CCF) — using proprietary models. ADVISORI guides you from model development through supervisory approval to ongoing validation — for risk-sensitive capital management under CRR III.

CRD Buffer Requirements

The CRD combined buffer requirement defines how capital conservation buffer, countercyclical buffer, systemic risk buffer and G-SII/O-SII buffers interact under a single framework. ADVISORI advises financial institutions on buffer stacking rules, capital distribution restrictions, MDA calculation and capital conservation planning — ensuring full compliance with the CRD buffer framework.

CRD Capital Adequacy

Capital adequacy requirements under the CRD comprise the overall capital requirement from Pillar 1 minimum, SREP capital add-on (P2R), combined buffer requirement, and Pillar 2 Guidance (P2G). We support banks in supervisory capital quantification, preparation for CRD VI changes, and integration of ESG risks into the capital adequacy assessment.

CRD Compliance

The Capital Requirements Directive (CRD VI) introduces stricter requirements for governance, fit-and-proper assessments, and ESG risk management. CRD compliance requires end-to-end processes from suitability assessments through internal control systems to ongoing supervisory reporting. ADVISORI supports credit institutions with comprehensive CRD compliance: gap analysis, governance framework design, and regulatory documentation.

CRD Conservation Buffer

The CRD Capital Conservation Buffer under Art. 129 CRD V/VI requires EU credit institutions to hold 2.5% Common Equity Tier 1 (CET1) capital above minimum requirements. When breached, the MDA (Maximum Distributable Amount) calculation triggers automatic distribution restrictions on dividends, bonuses, and AT1 coupons. ADVISORI advises on strategic buffer management, CRD VI implementation, and regulatory capital planning across the EU framework.

CRD Corporate Governance

The Capital Requirements Directive (CRD) defines comprehensive governance requirements for credit institutions across the EU — from fit-and-proper assessments to management body composition and remuneration policies. CRD VI adds ESG governance obligations and enhanced supervisory board duties. ADVISORI supports you in fully implementing all CRD governance requirements, preparing for suitability assessments, and establishing robust internal governance structures aligned with EBA guidelines.

CRD Countercyclical Buffer

The countercyclical capital buffer under Art. 130 CRD (Directive 2013/36/EU) requires credit institutions to maintain an institution-specific buffer as the weighted average of applicable national CCyB rates. The calculation under Art. 140 CRD considers the geographic distribution of credit risk exposures. ADVISORI supports you with CRD-compliant buffer calculation, ESRB reciprocity requirements and implementation of CRD VI changes effective January 2026.

CRD Credit Institution

The Capital Requirements Directive (CRD VI) imposes comprehensive requirements on credit institutions regarding governance, authorisation, and supervision. We support banks in the strategic implementation of all CRD requirements - from fit & proper assessments and internal governance structures to supervisory interaction. Our RegTech solutions make your CRD compliance efficient and sustainable.

CRD Credit Risk

End-to-end consulting for implementing the CRD credit risk framework: from the reformed Standardised Approach (SA-CR) and Output Floor calculations to ECAI due diligence requirements. We support your institution in the compliant implementation of CRR III capital requirements and the strategic optimisation of your risk weighting.

CRD Directive

The Capital Requirements Directive (CRD) is the core EU directive governing banking supervision, governance, and authorization of credit institutions. From CRD IV through CRD V to the current CRD VI, it defines the supervisory framework that each EU member state must transpose into national law. ADVISORI has been supporting banks and financial institutions with CRD implementation for over 14 years.

CRD Disclosure Report

The CRD requires credit institutions to maintain a transparent disclosure process with clear governance. We support banks in establishing three-line quality assurance, drafting the disclosure policy and preparing for the Pillar 3 Data Hub — so your disclosure report withstands supervisory scrutiny.

CRD EBA

The European Banking Authority (EBA) operationalises the CRD through binding guidelines on internal governance, remuneration policy, fit-and-proper assessments and ESG risk management. With CRD VI transposition due by January 2026 and the governance guidelines revision (EBA/CP/2025/20), banks face comprehensive adjustments. ADVISORI supports the structured implementation of all EBA requirements — from gap analysis and MaRisk compatibility review to supervisory dialogue.

CRD Fit and Proper

Fit and Proper ensures that members of the management body, supervisory board and key function holders meet regulatory requirements for knowledge, experience, integrity and time commitment. With CRD VI expanding the scope to key function holders and the revised EBA/ESMA joint guidelines introducing AML/CFT competence requirements, banks face growing complexity in their suitability assessment processes. ADVISORI supports you with systematic implementation of all Fit and Proper requirements across the EU framework.

CRD Governance

The CRD defines binding requirements for the internal governance of credit institutions – from the three lines of defence model through internal control systems to the independent compliance function. With the new EBA guidelines (EBA/CP/2025/20) and CRD VI, requirements for risk management governance, control functions, and organizational structures are tightening significantly. ADVISORI supports you with gap analysis, implementation, and ongoing monitoring of your internal governance framework aligned with EBA standards.

CRD IV

Directive 2013/36/EU (CRD IV) together with the CRR forms the regulatory foundation of EU banking supervision under Basel III. We support financial institutions in the full implementation of governance, SREP and Pillar 2 requirements — from gap analysis to supervisory-compliant implementation.

CRD IV Germany

The German implementation of the Capital Requirements Directive IV places specific demands on governance, risk management and BaFin interaction through the KWG and MaRisk framework. We guide banks through full CRD IV compliance in Germany — from gap analysis and SREP preparation to the implementation of compliant remuneration and governance structures.

CRD Internal Models

The use of internal models to calculate risk-weighted assets requires supervisory approval from the ECB and national authorities. We guide your institution through the entire IRB approval process — from model development and validation per the revised ECB guide 2025 to successful regulatory approval. With our expertise, you navigate the tightened CRD VI requirements, the output floor and internal model restrictions with confidence.

CRD Liquidity

The CRD establishes binding liquidity requirements for EU banks — from the Liquidity Coverage Ratio (LCR) and Net Stable Funding Ratio (NSFR) to internal liquidity risk management. ADVISORI supports financial institutions with regulatory implementation, liquidity governance and building robust stress testing frameworks.

CRD Liquidity Coverage Ratio

The Liquidity Coverage Ratio (LCR) requires credit institutions to hold sufficient high-quality liquid assets (HQLA) to cover net cash outflows over a 30-day stress scenario. The minimum ratio is 100%. Under the EU implementation of Basel III through CRR/CRD, Delegated Regulation 2015/61 governs HQLA categories, inflow/outflow rates, and reporting requirements. ADVISORI supports banks with compliant LCR calculation, HQLA optimization, and supervisory reporting.

CRD Market Discipline

CRD Market Discipline creates transparency and trust between financial institutions and stakeholders through Pillar 3 disclosure requirements. As a leading consulting firm, we develop tailored RegTech solutions for automated disclosure processes, intelligent risk communication and strategic transparency optimisation with full IP protection.

Frequently Asked Questions about CRR Model

What are the prerequisites for IRB approval under CRR?

Approval for the Internal Ratings-Based Approach (IRBA) requires a formal application to the competent authority pursuant to Art.

143 CRR. Institutions must demonstrate that their internal rating systems fully meet the requirements of Art.

143 to

191 CRR. This includes robust PD (Probability of Default) estimates for the Foundation IRB approach, plus own LGD and EAD estimates for the Advanced IRB approach.Key requirements include at least three years of system usage before application, complete documentation of model methodology, independent validation processes, and adequate data quality. The supervisor assesses whether all minimum requirements for data history, discriminatory power, calibration, and governance are met. Material model changes or scope extensions also require separate approval.ADVISORI supports credit institutions through the entire approval process — from model development and documentation to supervisory dialogue.

How do Foundation IRB and Advanced IRB differ in credit risk measurement?

Under the Foundation IRB approach (F-IRBA), institutions estimate only the Probability of Default (PD) using their own models. For Loss Given Default (LGD), Exposure at Default (EAD), and the Credit Conversion Factor (CCF), supervisory standard values apply.Under the Advanced IRB approach (A-IRBA), institutions additionally estimate LGD, EAD, and CCF with their own internal models. This requires more extensive data histories, more rigorous validation processes, and stronger model governance. Under CRR III, the scope of A-IRBA is restricted: for exposures to financial institutions and large corporates with consolidated annual revenue exceeding EUR

500 million, only F-IRBA is permitted. Additionally, input floors apply for PD (minimum 0.05%), LGD, and CCF, preventing model estimates from producing excessively low values.The choice of approach directly impacts the level of risk-weighted assets (RWA) and consequently capital requirements.

What does the output floor mean for banks using internal models?

The output floor under Art. 92a CRR III limits the capital benefit that banks can achieve through internal models compared to the Standardised Approach (SA). From 2025, risk-weighted assets (RWA) calculated using internal models may not fall below a specified percentage of SA-calculated RWA.Implementation is phased: 50% from January 2025, increasing annually by

5 percentage points to 72.5% by 2030. This means IRBA banks must maintain a full parallel SA calculation alongside their internal models. Institutions whose IRB models previously achieved significant capital advantages over the standardised approach must expect higher own funds requirements.Banks should conduct portfolio-specific impact analyses early to assess which exposure classes remain economically viable under IRBA and where switching to the SA may be more advantageous.

What CRR requirements apply to internal market risk models (IMA/FRTB)?

With the implementation of the Fundamental Review of the Trading Book (FRTB) through CRR III, requirements for internal market risk models (Internal Model Approach, IMA) are fundamentally revised. The previous Value-at-Risk approach is replaced by Expected Shortfall as the central risk measure.Institutions wishing to use IMA must apply for approval at individual trading desk level. Each desk must pass a Profit-and-Loss Attribution Test (PLA) and a backtesting test. Desks failing these tests automatically fall back to the Standardised Approach (SA-TB). Capital requirements under FRTB-IMA comprise Expected Shortfall, a Stressed Expected Shortfall component, and a Default Risk Charge.The approval threshold has risen significantly, leading many institutions to evaluate whether switching to the standardised approach is more economical for certain desks. ADVISORI supports desk-level analysis and strategic FRTB implementation.

How are PD, LGD, and EAD models validated under CRR III?

Validation of PD, LGD, and EAD models under CRR III follows a structured framework based on Art.

174 to

191 CRR and EBA guidelines on model validation. Independent validation must occur at least annually and cover all model components.For PD models, validation includes discriminatory power analysis (Gini coefficient, Accuracy Ratio), calibration tests, and stability analysis across different time periods. LGD models are tested by comparing realised loss rates against estimated values, validating both downturn LGD and long-term averages. EAD models and CCF estimates are verified by comparing actual drawdown at default with model predictions.Under CRR III, additional input floors apply (PD minimum 0.05%, LGD minimum 25% for unsecured corporate exposures), ensuring model estimates do not fall below regulatory minimums. Validation must document correct application of these floors.

What impact does CRR III have on the economics of internal models?

CRR III fundamentally changes the cost-benefit calculation for internal models. The output floor (72.5% of SA-RWA) caps the maximum capital advantage of IRBA over the standardised approach at 27.5%. Meanwhile, costs for model development, validation, governance, and IT infrastructure remain.Institutions must assess on a portfolio-by-portfolio basis whether the remaining capital benefit justifies model maintenance costs. Analyses show that particularly for mid-sized banks with total assets between EUR

5 and

30 billion, selective IRBA application to specific exposure classes may be more economical than blanket usage.Assessment factors include: current difference between IRB and SA RWA per portfolio, costs of parallel SA calculation (output floor requirement), regulatory change frequency, and the strategic value of granular risk data for internal management. ADVISORI conducts detailed economic analyses and develops optimal model strategies under CRR III.

How does ADVISORI support CRR model implementation?

ADVISORI supports credit institutions across all aspects of CRR model implementation and optimisation. Our services encompass strategic model planning, quantitative model development, preparation for supervisory approval, and ongoing model maintenance.For IRB approval, we support development and calibration of PD, LGD, and EAD models, preparation of audit-proof documentation, and dialogue with supervisory authorities. For the output floor, we conduct portfolio-specific impact analyses and develop optimal strategies combining IRBA and SA.For FRTB implementation, we analyse IMA economics per trading desk and support implementation of PLA test and backtesting infrastructure. Our model validation teams perform independent reviews per EBA guidelines and identify optimisation potential. Through regular regulatory updates, we keep our clients’ models aligned with current requirements.

Success Stories

Discover how we support companies in their digital transformation

Digitalization in Steel Trading

Klöckner & Co

Digital Transformation in Steel Trading

Case Study
Digitalisierung im Stahlhandel - Klöckner & Co

Results

Over 2 billion euros in annual revenue through digital channels
Goal to achieve 60% of revenue online by 2022
Improved customer satisfaction through automated processes

AI-Powered Manufacturing Optimization

Siemens

Smart Manufacturing Solutions for Maximum Value Creation

Case Study
Case study image for AI-Powered Manufacturing Optimization

Results

Significant increase in production performance
Reduction of downtime and production costs
Improved sustainability through more efficient resource utilization

AI Automation in Production

Festo

Intelligent Networking for Future-Proof Production Systems

Case Study
FESTO AI Case Study

Results

Improved production speed and flexibility
Reduced manufacturing costs through more efficient resource utilization
Increased customer satisfaction through personalized products

Generative AI in Manufacturing

Bosch

AI Process Optimization for Improved Production Efficiency

Case Study
BOSCH KI-Prozessoptimierung für bessere Produktionseffizienz

Results

Reduction of AI application implementation time to just a few weeks
Improvement in product quality through early defect detection
Increased manufacturing efficiency through reduced downtime

Let's

Work Together!

Is your organization ready for the next step into the digital future? Contact us for a personal consultation.

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Our clients trust our expertise in digital transformation, compliance, and risk management

Ready for the next step?

Schedule a strategic consultation with our experts now

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Desired business outcomes and ROI expectations
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