Proportionate market risk capital calculation for banks with small trading books

FRTB Simplified Standardised Approach (SSA)

Not every bank needs the full FRTB standardised approach.

  • 01Lower implementation effort compared to the full standardised approach (SA)
  • 02Regulatory-approved scaling factors per risk class
  • 03Clear eligibility criteria under CRR III Art. 325a
  • 04Proportionate solution for banks without complex trading activities
11+Years of experience
120+Employees
540+Projects
ISO 27001certified

What is the Simplified Standardised Approach (SSA) under FRTB?

The Simplified Standardised Approach (SSA) is a simplification of the sensitivity-based standardised approach for market risk, anchored in the Basel framework and CRR III. It is designed for institutions whose trading book does not exceed defined thresholds. Instead of the full delta-vega-curvature calculation, the SSA applies flat scaling factors per risk class — interest rate risk (1.3), equity risk (3.5), commodity risk (1.9) and foreign exchange risk (1.2).

ADVISORI supports banks with the complete SSA implementation: from eligibility assessment through scaling factor calibration to supervisory documentation.

2 service modules

What we take on for you

Bookable individually or as an end-to-end programme.

01

SSA Eligibility Analysis and Implementation

Assessment of prerequisites for the simplified standardised approach and complete implementation of the capital calculation under CRR III.

  • Threshold review under CRR III Art. 325a and supervisory guidance
  • Calibration of scaling factors per risk class (interest rate, equity, commodity, FX)
  • DRC calculation and Residual Risk Add-On alongside the SSA
  • Non-arbitrage proof and supervisory documentation
02

Ongoing SSA Compliance and Threshold Monitoring

Continuous monitoring of eligibility criteria and adjustment of capital calculations when the trading book changes.

  • Quarterly threshold monitoring and early warning system when approaching limits
  • Transition strategy if SSA thresholds are exceeded to full SA
  • Regulatory reporting for market risk own funds requirements
  • Training on SSA methodology and proportionality rules

5 phases

Our Approach

We guide institutions step by step through the SSA implementation — from initial eligibility analysis to ongoing operations.

  1. Assessment

    analysis of current trading book size, product complexity and risk class structure

  2. Eligibility review

    comparison against CRR III thresholds (below EUR 1bn trading book, non-G-SIB/D-SIB, no correlation trading portfolios)

  3. Capital calculation

    implementation of four risk classes with regulatory scaling factors

  4. Documentation

    preparation of non-arbitrage proof versus the full SA

  5. Operating model

    establishment of ongoing threshold monitoring and periodic validation

Your contact

Melanie Düring

Head of Risk Management

Implementing the Simplified Standardised Approach showed us that proportionality in regulation works. With the SSA, we can meet FRTB requirements efficiently without overloading our resources.

Why ADVISORI

  • 01Experience from FRTB projects at institutions of various sizes
  • 02Deep understanding of CRR III proportionality rules and supervisory expectations
  • 03Pragmatic implementation focused on regulatory acceptance
  • 04Holistic approach: SSA, DRC, trading book boundary and reporting

Deadline note

FRTB capital requirements take effect on 1 January 2027. A further postponement by the EU Commission alone is not possible. Institutions should assess SSA eligibility now.

5 QUESTIONS, BRIEFLY ANSWERED

Frequently asked questions about FRTB Simplified Standardised Approach (SSA) — Proportionality for Small Trading Books

Which banks are eligible for the FRTB Simplified Standardised Approach?

Eligibility is anchored in CRR III Art. 325a and follows the proportionality logic of the Basel framework. The core criteria: the institution's on- and off-balance-sheet trading book business must remain below the defined size thresholds — below EUR 1 billion and a limited share of total assets — the institution must not be a G-SIB or O-SII, and it must not hold correlation trading portfolios or pursue complex trading strategies for which the simplified approach was not designed. Eligibility is not a one-off gate: institutions must monitor the thresholds on an ongoing basis and demonstrate continued compliance to the supervisor. We conduct a structured eligibility assessment that reviews trading book size, product complexity and risk class structure, and documents the result in a form that stands up to supervisory dialogue.

How is capital calculated under the SSA, and how does it differ from the full standardised approach?

The SSA dispenses with the full sensitivities-based method of the FRTB standardised approach — no delta, vega and curvature calculations, no correlation scenarios. Instead, capital is calculated using recalibrated versions of the previous standardised market risk approaches, multiplied by supervisory scaling factors per risk class: 1.3 for interest rate risk, 3.5 for equity risk, 1.9 for commodity risk and 1.2 for foreign exchange risk. This drastically reduces data requirements: no sensitivity infrastructure, no bucketing across dozens of risk factor categories, and significantly simpler validation. The trade-off is risk sensitivity — the flat scaling factors do not reward hedging and diversification the way the full SA does. For banks with small, straightforward trading books, however, the operational simplification usually outweighs this drawback.

Is the SSA always the more economical choice for a small trading book?

Not automatically — the decision has two dimensions.

🔍 Implementation and running costs:

• The SSA avoids the sensitivity infrastructure, data sourcing and validation effort of the full SA, which is a substantial saving for small institutions
• Ongoing operations are simpler: fewer models, fewer data feeds, leaner reporting.

🔍 Capital effects:

• The conservative scaling factors, especially 3.5 for equity risk, can produce higher capital requirements than the full SA for the same portfolio
• Portfolios with significant hedging or diversification benefit less, because the SSA recognizes these effects only to a limited extent. The right answer therefore depends on your portfolio structure. We quantify both dimensions in a comparative calculation, so the choice between SSA and full SA rests on numbers rather than assumptions.

What happens if our trading book grows beyond the eligibility thresholds?

Threshold breaches are the key operational risk of the SSA. Institutions must monitor the CRR III criteria continuously, and a sustained breach obliges the bank to transition to the full standardised approach — a project that requires sensitivity calculations, new data feeds and adjusted processes, and that cannot be delivered overnight. Prudent SSA users therefore establish three safeguards: first, monthly threshold monitoring with early-warning indicators well below the hard limits; second, governance rules that flag planned business growth or new products against the eligibility criteria before they are launched; and third, a documented contingency plan describing how a migration to the full SA would be executed, with realistic timelines. We set up this monitoring and contingency framework as part of every SSA implementation, so growth decisions never collide unexpectedly with regulatory eligibility.

What does the EU measures package of November 2025 change for the SSA?

The EU measures package of November 2025 adjusts the FRTB framework in the EU, and one element is directly relevant for SSA users: the diversification multiplier, previously a relief mechanism within the full standardised approach, is extended to the Simplified Standardised Approach. For institutions using the SSA this is a meaningful improvement, because it softens the main drawback of the approach — the limited recognition of diversification across risk classes — and thereby improves the capital outcome without adding implementation complexity comparable to the full SA. The practical consequence: banks that previously ruled out the SSA on capital grounds should re-run the comparison against the full SA under the updated rules. We update the comparative calculation, verify the correct application of the multiplier and adjust your capital calculation and documentation accordingly.

Certificates, partners and more

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

Your strategic success starts here

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

30 Minutes • Non-binding • Immediately available

For optimal preparation of your strategy session:

Your strategic goals and challenges
Desired business outcomes and ROI expectations
Current compliance and risk situation
Stakeholders and decision-makers in the project

Prefer direct contact?

Direct hotline for decision-makers

Strategic inquiries via email

Detailed Project Inquiry

For complex inquiries or if you want to provide specific information in advance