CRR III: The new Capital Requirements Regulation and its impact on real estate

The Capital Requirements Regulation III (CRR III) came into force on 1 January 2025, bringing about fundamental changes in calculating risk-weight assets (RWA) for banks operating within the European Union. The CRR III reform is designed to bolster the banking sector's resilience and ensure a more transparent and risk-sensitive approach to determining capital requirements, including increased capital buffers and differentiated risk exposure classes. Particular emphasis is placed on real estate finance, especially commercial real estate (CRE) and residential real estate (RRE), which are significantly affected by these new rules.

In this article, we delve into the background and meaning of CRR III, its specific implications for the real estate sector, and how banks can meet these new demands.

What exactly is CRR III?

Often referred to as the “Finalisation of Basel III” or even “Basel IV,” CRR III builds upon the Basel III rules as established by the Basel Committee on Banking Supervision (BCBS). Together with related amendments in the capital requirements directive (CRD VI), these rules have been further refined by the European Banking Authority (EBA) to incorporate modern risk frameworks—including market risk considerations, stress testing methodologies, and loss rates analysis. Despite delays caused by the pandemic, the European Commission suggested 1 January 2025 as the commencement date. This proposal was preceded by negotiations between the Council of the European Union and the European Parliament, followed by extensive interinstitutional trilogue talks in 2023.

The aim is to strengthen the European banking sector’s resilience through more transparent and risk-sensitive procedures—utilising internal models and optimised reporting requirements. Additionally, modern approaches such as the Internal Ratings-Based (IRB) approach are supported to enhance the credit-granting process and the regulatory assessment of both loan and whole-loan exposures. Compared to CRR II, aspects like the Credit Risk Standardised Approach (CRSA) and the Credit Conversion Factor (CCF) are now factored into calculating credit risk and capital requirements. At the same time, central banks play a crucial role in overseeing the framework's implementation.

What does this mean for real estate?

The implementation of CRR III brings significant changes to the real estate sector – particularly regarding the risk weighting of real estate-secured exposures. A key distinction is made between types of exposures, such as properties (residential real estate and commercial real estate), where repayments are primarily sourced from the cash flow generated by the property (IPRE, Income Producing Real Estate Exposure) and those where this is not the case. Unsecured IPRE positions will now be assigned a risk weight of 150%, reflecting updated technical standards and more rigorous market risk assessments. This adjustment is set to significantly impact the balance sheet of credit institutions, resulting in a notable increase in risk-weighted assets (RWA) and, consequently, higher own-funds requirements as per the revised prudential framework.

CRR III also impacts mortgage exposures and the treatment of land acquisition, development, and construction (ADC) loans. These exposures are subject to stricter risk weighting, particularly in markets where the loan-to-value (LTV) ratios exceed predefined thresholds. Covered bonds backed by immovable property could receive preferential risk weights under certain conditions, offering some relief for lenders specialising in mortgage-backed securities.

The new rules mandate that banks conduct a detailed analysis of their real estate portfolios and maintain continuous monitoring, aligning with enhanced reporting requirements and supervisory directives issued by competent authorities across member states. Beyond simply adjusting risk weights, data analysis is becoming paramount. Banks can manage and potentially optimise the additional capital burden imposed by higher risk weights by closely monitoring the market value, revaluation trends, and risk assessments of properties. Furthermore, the integration of ESG risks is playing an increasingly important role in promoting sustainable real estate financing and addressing future challenges.

Impact on different banking models

The effects of CRR III are not uniform across all banks. Depending on their business model, the consequences can vary significantly. Large, internationally active banks that rely on complex internal models (Internal Ratings-Based Approach, or IRBA) face the challenge of meeting the Output Floor – a minimum threshold for capital requirements – which can substantially increase required capital buffers. IRBA institutions often need to fundamentally adjust their risk models and loan portfolios to comply with the new standards.

In contrast, smaller banks or those primarily lending to SMEs (small and medium-sized enterprises) and utilising the standardised approach are less affected. In particular, the SME supporting factor can help ensure that these banks are less burdened by the new regulations. This illustrates that the impact of CRR III largely depends on the size and business model of the institution – whether it operates on an international scale or remains more regionally focused with an emphasis on the SME sector.

How can banks implement CRR III requirements?

Since CRR III entered force on 1 January 2025, banks have been tasked with effectively implementing the new regulatory framework – from increased capital buffers to liquidity and credit risk methodologies adjustments. In doing so, they must consider elements such as derivatives exposure, the internal ratings-based approach, and market risk assessments while addressing key risk factors and adapting to evolving trends in financial services. By adopting a robust model approach and aligning with updated prudential requirements, banks can ensure a level playing field within the evolving European banking package. To manage the additional capital needs, financial institutions should consider the following measures:

By proactively adopting these measures, banks can meet the complex regulatory demands of CRR III, strengthen their market position, and benefit from a long-term, sustainable business model.

Practical challenges in implementation

Besides substantive changes, the introduction of CRR III brings significant practical challenges. Banks must fundamentally overhaul their IT systems and data management processes to accommodate the higher data granularity and new risk modelling requirements – often requiring extensive system modifications and establishing additional data sources and validations.

Moreover, comprehensive staff training programmes are essential, as all departments—from risk management and controlling to IT and compliance—require realignment. Coordination between internal teams and external regulatory bodies is often complex. These challenges demand technical investments, strategic reorientation, and ongoing operational adjustments.

Innovative solutions to meet CRR III

The introduction of CRR III represents a pivotal step in strengthening the stability of Europe’s banking sector. The new rules, particularly in the real estate arena, result in a markedly higher capital requirement – especially for unsecured IPRE risk positions. Banks are now challenged to reassess their portfolios through precise data analysis and continuous monitoring. Institutions can navigate these complex regulatory requirements with innovative solutions while strategically leveraging integrated ESG data and optimised risk models. Banks can efficiently manage capital needs and enhance financial stability with advanced real estate valuation and risk management solutions. They ensure compliance with the latest prudential requirements while considering the evolving landscape of borrower, obligor, and counterparty risk.

PriceHubble’s AI-driven property performance systems empower banks to accurately value and monitor their real estate portfolios. In particular, when capturing and analysing the key metrics relevant to CRR III – such as risk weights – PriceHubble’s advanced solutions provide real-time monitoring and scenario analysis. Moreover, our platform supports the integration of ESG data into valuation models, helping banks meet CRR III standards and promote sustainable financing. Through detailed risk modelling, banks can transparently assess the impact of the new risk weights on their capital ratios and adjust their strategies accordingly.

With PriceHubble’s property performance systems, you can optimise your real estate portfolio to meet CRR III requirements.