COVID-19: a stress test of bank regulatory reforms - A proposal for the 2021 review of bank capital and liquidity buffers

Sep 4, 2026

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Global banking regulation was overhauled after the 2008–09 financial crisis, introducing new liquidity management principles, higher capital requirements, and widespread stress-testing. The reforms improved resilience yet produced unintended effects, including fragmentation of rules across jurisdictions and resulting uncertainty and inefficiencies. The document evaluates system performance during COVID-19, noting banks generally acted as part of the solution, while emphasizing the role of extraordinary fiscal and monetary measures. It argues the 2021 FSB review must assess buffer design and lessons from pre-pandemic issues.

LanguageEnglish

CategoryResearch & Report

FormatPDF

Pages15

Reading Time38 min

AccessFree to download

Summary

Introduction

Post-crisis reforms and regulatory approaches

COVID-19 waves and banking system performance

Rationale for the 2021 FSB review

Briefing Paper Global Economy and Finance Programme March 2021 Rebecca Emerson and Til Schuermann COVID-19: a stress test of bank regulatory reforms A proposal for the 2021 review of bank capital and liquidity buffers Summary — The bank regulatory framework was completely overhauled at both the international and local level following the 2008–09 global financial crisis. Key changes included the introduction of new principles for liquidity management, increased capital requirements and the widespread introduction of stress-testing. — The reforms strengthened the global banking system, but they also had a number of unintended consequences. Among other things, they allowed a degree of Balkanization of bank capital and liquidity rules, creating a patchwork of local-level regulation that has led to uncertainty and inefficiencies. — Despite drawbacks, the new system has generally performed well to date during the COVID-19 pandemic, with banks being part of the solution (in terms of mitigating the financial impact of the crisis) rather than the problem. However, to a substantial extent this has been due to unprecedented fiscal and monetary measures undertaken by the authorities. — The Financial Stability Board’s 2021 review of the regulatory system’s performance during the pandemic will be critical to future international coherence. To be successful, it must fully explore key questions concerning the system of capital and liquidity buffers, including whether an optimal balance was struck between the use of regulatory protections and the deployment of exceptional economic and financial measures. The review must also address problems that were emerging before the pandemic. COVID-19: a stress test of bank regulatory reforms A proposal for the 2021 review of bank capital and liquidity buffers Introduction In the wake of the financial crisis of 2008–09, the banking regulatory framework was overhauled both at the global and local1 level. At the global level, the Basel Committee on Banking Supervision (BCBS)2 developed new principles for liquidity management and increased capital requirements.3 At the local level, regulators ina number of jurisdictions significantly changed their calculations of the necessary levels of liquidity and capital: in the US, for example, the Federal Reserve put in place the Comprehensive Capital Analysis and Review (CCAR) mechanism, an annual stress-testing and capital planning exercise; in the EU, the European Central Bank (ECB) put in place the Supervisory Review and Evaluation Process (SREP), a bi-annual process to assess banks’ risk profiles and make supervisory decisionson capital and liquidity, supported by insights from the European Banking Authority’s bi-annual stress test; and in the UK, the Prudential Regulation Authority (PRA) set out a new approach based around stress-testing to inform capital requirements.4 These and other measures have resulted in banks building up substantial capital and liquidity buffers in the past few years. The initial financial market shock from COVID-19, from mid-March to mid-April 2020, provided the first major test of these changes. On the whole, the banks came through this period of volatility relatively well, albeit supported by central bank intervention and fiscal programmes of unprecedented scale.5 Additional market turbulence occurred in October 2020 and January 2021 during the subsequent second and third waves of infections, but this volatility was less pronounced than during the first wave. The arrival of apparently effective vaccines in late November and December 2020, following successful trials, has reduced uncertainty about the duration of the pandemic, at least in parts of the developed world. That said, the macroeconomic effects of the pandemic, and its impact on bank balance sheets, will continue to feed through into financial markets and banking systems, which could lead to further turbulence. Although the overall effect on ban

FAQs

What major regulatory changes followed the 2008–09 financial crisis?

The framework was overhauled with new liquidity management principles, increased capital requirements, and the widespread introduction of stress-testing.

How did the regulatory system perform during the COVID-19 pandemic?

Banks generally performed well during COVID-19 volatility, but this outcome relied substantially on unprecedented fiscal and monetary measures by authorities.

What should the 2021 Financial Stability Board review focus on?

It must fully explore the balance and effectiveness of capital and liquidity buffers, including whether regulatory protections were optimally complemented by exceptional economic and financial measures, and it should also address issues emerging before the pandemic.

Sep 4, 2026

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