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. The Simplified Standardised Approach (SSA) offers institutions with small or medium trading books a regulatory-approved alternative with reduced implementation effort — while maintaining full CRR III compliance.

  • Lower implementation effort compared to the full standardised approach (SA)
  • Regulatory-approved scaling factors per risk class
  • Clear eligibility criteria under CRR III Art. 325a
  • Proportionate solution for banks without complex trading activities

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

Why ADVISORI

  • Experience from FRTB projects at institutions of various sizes
  • Deep understanding of CRR III proportionality rules and supervisory expectations
  • Pragmatic implementation focused on regulatory acceptance
  • Holistic 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.

ADVISORI in Numbers

11+

Years of Experience

120+

Employees

520+

Projects

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

Our Approach:

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

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

Capital calculation: implementation of four risk classes with regulatory scaling factors

Documentation: preparation of non-arbitrage proof versus the full SA

Operating model: establishment of ongoing threshold monitoring and periodic validation

"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."
Melanie Düring

Melanie Düring

Head of Risk Management

Our Services

We offer you tailored solutions for your digital transformation

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

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

Our Competencies

Choose the area that fits your requirements

Expected Shortfall Under FRTB – Calculation, Validation and Implementation

Expected Shortfall (ES) is the central risk measure for market risk capital requirements under the Fundamental Review of the Trading Book (FRTB). It replaces Value at Risk and measures the average loss in the tail of the loss distribution — at the 97.5% confidence level over a 250-day stress period. ADVISORI guides banks through implementation: from ES calculation through classification of modellable risk factors to regulatory validation.

FRTB Backtesting Requirements — Model Validation Standards for Market Risk

FRTB Backtesting Requirements demand precise implementation of Basel III model validation with specific backtesting performance requirements and validation procedures. As a leading consulting firm, we develop tailored RegTech solutions for intelligent backtesting compliance, automated model performance monitoring, and strategic validation optimization with full IP protection.

FRTB Boundary Trading Banking Book

The correct delineation between the trading book and banking book is critical for FRTB compliance and capital optimization. Together with you, we develop solid boundary management frameworks for precise classification and efficient management.

FRTB Credit Valuation Adjustment

FRTB Credit Valuation Adjustment presents new challenges for capital calculation and risk management. Together with you, we develop comprehensive CVA frameworks for precise capital calculation, effective hedging, and sustainable compliance excellence.

FRTB Data Management

The Fundamental Review of the Trading Book demands comprehensive market data, demonstrable risk factor modellability and audit-proof data governance. We build the data infrastructure your trading book needs — from real price observation pipelines and NMRF minimisation to automated data quality assurance.

FRTB German Implementation

The Fundamental Review of the Trading Book presents German banks with specific challenges. We develop tailored implementation strategies that meet BaFin requirements while accounting for the particularities of the German banking market.

FRTB Implementation

Navigate the complex implementation of the Fundamental Review of the Trading Book with our comprehensive implementation support. We guide you through the entire process – from the initial assessment and gap analysis through concept development and system adaptation to full integration into your trading and risk management systems, including model adjustment, data infrastructure and process optimisation.

FRTB Implementation Strategy: Approach Selection, Capital Optimization & Phased Rollout

FRTB Implementation Strategy requires precise implementation of the Basel III Fundamental Review of the Trading Book with specific market risk capital requirements and supervisory validation. As a leading AI consultancy, we develop tailored RegTech solutions for intelligent FRTB compliance, automated trading book separation and strategic market risk optimization with full IP protection.

FRTB Internal Models Approach (IMA) — Requirements, Approval and Implementation

The FRTB Internal Models Approach (IMA) allows banks to use their own risk models for market risk capital calculations — provided they meet strict supervisory requirements for Expected Shortfall, backtesting and P&L attribution. As specialist FRTB consultants, ADVISORI supports institutions with IMA approval, model validation and ongoing compliance.

FRTB Market Risk Modeling – Sensitivity-Based Approach, Risk Classes & Risk Factor Modeling

The Fundamental Review of the Trading Book requires fundamentally new market risk modeling: The sensitivity-based approach (SbA) calculates delta, vega and curvature risks across seven risk classes – GIRR, CSR (non-sec, sec CTP, sec non-CTP), equity, FX and commodity. We support banks in the methodological design, risk factor modeling and operational implementation of these requirements.

FRTB Non-Modellable Risk Factors (NMRF) – RPO Test & SES Capital Add-On | ADVISORI

FRTB Non-Modellable Risk Factors require precise implementation of Basel III NMRF identification with specific capital calculation procedures and stress scenario calibration. As a leading AI consultancy, we develop tailored RegTech solutions for intelligent NMRF compliance, automated risk factor validation and strategic supervisory recognition optimization with full IP protection.

FRTB Ongoing Compliance

Ongoing adherence to FRTB requirements demands systematic monitoring, regular adjustments, and proactive optimization. We support you in establishing sustainable FRTB compliance.

FRTB P&L Attribution Test (PLAT) – Requirements, Methodology & Consulting | ADVISORI

FRTB Profit & Loss Attribution requires precise implementation of Basel III P&L allocation with specific risk factor decomposition requirements and model validation. As a leading AI consultancy, we develop tailored RegTech solutions for intelligent P&L attribution compliance, automated backtesting integration and strategic transparency optimisation with full IP protection.

FRTB Readiness Assessment

Our comprehensive FRTB readiness assessment identifies gaps in your current systems, processes, and data, quantifies the impact on your capital, and delivers a tailored implementation roadmap for efficient FRTB compliance.

FRTB Standardised Approach (SA): Sensitivity-Based Method, DRC & RRAO

The FRTB Standardised Approach requires precise implementation of Basel III sensitivity-based methods with specific market risk capital requirements and supervisory validation. As a leading AI consultancy, we develop tailored RegTech solutions for intelligent standardised approach compliance, automated sensitivity calculation and strategic market risk optimisation with full IP protection.

FRTB Technology Infrastructure

Successful FRTB implementation requires solid, flexible, and intelligent technology infrastructures. We develop tailored IT architectures that not only meet regulatory requirements but also increase operational efficiency and create competitive advantages.

FRTB Trading Desk Approval — Desk-Level IMA Approval, PLAT & Desk Structure

Trading desk approval is a core element of FRTB implementation: every desk seeking to use the Internal Models Approach (IMA) must pass the P&L Attribution Test (PLAT) and the Risk Factor Eligibility Test (RFET). ADVISORI supports banks with desk definition, desk-level IMA approval and ongoing monitoring of all approval criteria.

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.

Success Stories

Discover how we support companies in their digital transformation

Digitalization in Steel Trading

Steel trading company from Germany

Digital Transformation in Steel Trading

Case Study

Results

Over 2 billion euros in annual revenue through digital channels
More than half of revenue through online channels as a strategic goal
Improved customer satisfaction through automated processes

AI-Powered Manufacturing Optimization

Industrial group from Germany

Smart Manufacturing Solutions for Maximum Value Creation

Case Study

Results

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

AI Automation in Production

Automation specialist from Germany

Intelligent Networking for Future-Proof Production Systems

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

Generative AI in Manufacturing

Technology group from Germany

AI Process Optimization for Improved Production Efficiency

Case Study

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.

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

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Desired business outcomes and ROI expectations
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