The Financial Stability Board’s 2025 list identifies 29 global systemically important banks distributed across four populated buckets, with JPMorgan Chase alone in bucket 4 carrying a 2.5% Common Equity Tier 1 surcharge. Bank of America and Industrial and Commercial Bank of China moved from bucket 2 to bucket 3, while Deutsche Bank moved from bucket 2 to bucket 1.
The higher loss absorbency requirement established with this list will be effective beginning 1 January 2027 if there is a bucket increase. The 14-month gap between the November announcement and the January 2027 effective date is where readers misread the compliance timeline.
Key Takeaways
- The FSB’s 2025 list identifies 29 global systemically important banks, the same population as 2024 but with a different bucket allocation across five tiers.
- Bank of America and ICBC moved up from bucket 2 to bucket 3, lifting their Higher Loss Absorbency requirement from 1.5% to 2.0% of risk-weighted assets.
- Deutsche Bank moved down from bucket 2 to bucket 1, reducing its required surcharge from 1.5% to 1.0%.
- JPMorgan Chase remains the only bank in bucket 4 at 2.5%, while bucket 5 (3.5%) stays empty by design.
- The Basel Committee’s cutoff score sits at 130 basis points, with five categories weighted equally at 20% each.
- The BCBS end-2024 size denominator reached €111.3 trillion in total exposures, up from €66.3 trillion at end-2013.
- All bucket changes flowing from the 2025 list take effect on 1 January 2027, fourteen months after the FSB publication date.
Editor’s Choice
- The 2025 G-SIB list was published by the FSB on 27 November 2025, using end-2024 data.
- The Higher Loss Absorbency ladder runs from 1.0% at bucket 1 to a top populated tier of 2.5% at bucket 4, with bucket 5 at 3.5% held empty.
- Bucket 3 holds 4 banks after the 2025 reshuffle: Bank of America, Citigroup, HSBC, and ICBC, all carrying the 2.0% CET1 surcharge.
- 15 of the 29 banks sit in bucket 1, the lowest populated tier, carrying the 1.0% surcharge.
- The full G-SIB population spans 11 national jurisdictions, with the United States contributing 8 of the 29 banks for the largest single-country share.
- The BCBS payments denominator for end-2024 totalled 3,448,906 in € billions, a single-year flow measure across the assessment sample.
- The bucket-increase compliance date is 1 January 2027, the FSB’s standard fourteen-month lag from announcement to effective date.
Global Systemically Important Banks by Bucket
- JP Morgan Chase sits alone in bucket 4 (2.5%) in the 2025 list.
- Bucket 3 (2.0%) contains four banks: Bank of America, Citigroup, HSBC, and Industrial and Commercial Bank of China.
- Bucket 2 (1.5%) contains nine banks: Agricultural Bank of China, Bank of China, Barclays, BNP Paribas, China Construction Bank, Goldman Sachs, Groupe Crédit Agricole, Mitsubishi UFJ FG, and UBS.
- Bucket 1 (1.0%) contains fifteen banks: Bank of Communications, Bank of New York Mellon, Deutsche Bank, Groupe BPCE, ING, Mizuho FG, Morgan Stanley, Royal Bank of Canada, Santander, Société Générale, Standard Chartered, State Street, Sumitomo Mitsui FG, Toronto Dominion, and Wells Fargo.
- Bucket 5 (3.5%) is empty in the 2025 list, as it was in the 2024 list.
| Bucket | HLA (CET1 surcharge) | Bank count | Banks |
|---|---|---|---|
| 5 | 3.5% | 0 | (Empty) |
| 4 | 2.5% | 1 | JP Morgan Chase |
| 3 | 2.0% | 4 | Bank of America, Citigroup, HSBC, ICBC |
| 2 | 1.5% | 9 | Agricultural Bank of China, Bank of China, Barclays, BNP Paribas, China Construction Bank, Goldman Sachs, Groupe Crédit Agricole, Mitsubishi UFJ FG, UBS |
| 1 | 1.0% | 15 | BoCom, BNY Mellon, Deutsche Bank, Groupe BPCE, ING, Mizuho FG, Morgan Stanley, RBC, Santander, Société Générale, Standard Chartered, State Street, Sumitomo Mitsui FG, Toronto Dominion, Wells Fargo |
Source: FSB 2025 List of G-SIBs (P271125.pdf, 27 November 2025)
By the numbers: Per the FSB 2025 G-SIB list, JPMorgan Chase carries a 2.5% additional CET1 surcharge alone in bucket 4, while fifteen banks sit in bucket 1 at the 1.0% floor, with any bucket-driven changes binding regulatory capital plans across the 29 named institutions from 1 January 2027.
How do the buckets work?
The bucket approach assigns each G-SIB to a tier corresponding to a required level of additional common equity loss absorbency as a percentage of risk-weighted assets. The HLA requirement is to be met with Common Equity Tier 1 capital as defined by the Basel III framework. Banks higher up the ladder need to fund more capital against the same balance sheet, which is the regulatory tool the framework uses to internalise the externality of systemic failure.
Methodology and Indicators
- The methodology gives an equal weight of 20% to each of the five categories of systemic importance: size, cross-jurisdictional activity, interconnectedness, substitutability/financial institution infrastructure, and complexity.
- The current cutoff score is set at 130 basis points.
- The cutoff score and bucket thresholds were calibrated using end-2012 data such that the magnitude of the HLA requirement for the highest populated bucket is 2.5% of risk-weighted assets, with an initially empty top bucket of 3.5% of risk-weighted assets.
- The end-2024 size denominator reached 111,282 (in € billions) for total exposures, up from 66,313 at end-2013.
- The G-SIB dashboard shows the scores and components for global systemically important banks since 2014.
| End-Year | Size Denominator (€ billions) |
|---|---|
| End-2013 | 66,313 |
| End-2014 | 73,847 |
| End-2015 | 72,858 |
| End-2016 | 75,901 |
| End-2017 | 73,020 |
| End-2018 | 75,921 |
| End-2019 | 81,321 |
| End-2020 | 85,114 |
| End-2021 | 98,475 |
| End-2022 | 102,639 |
| End-2023 | 104,258 |
| End-2024 | 111,282 |
Source: BCBS G-SIB Framework: Denominators (end-2024 exercise)
Key finding: Per BCBS d445, each of the five systemic-importance categories carries an equal 20% weight, with the cutoff score set at 130 basis points and bucket thresholds calibrated using end-2012 data so the top populated bucket commands a 2.5% CET1 surcharge while bucket 5 sits empty by design.
Supervisory judgment overlay
The scores and bucket allocations represent the outcome of the mechanistic elements of the G-SIB methodology and include the exercise of supervisory judgement. In the latter case, a bank may be in a bucket despite its score being above or below the relevant threshold.
The supervisory overlay is the framework’s release valve, used to handle banks whose mechanistic score does not reflect their actual systemic profile.
The forward effective date
The capital buffer requirements for the G-SIBs identified in the annual update each November will apply to them as of January, fourteen months later. Stated plainly: the November 2025 list takes effect on 1 January 2027, the next-but-one January after publication. Bank treasury teams plan for the effective date, not the announcement date.
Recent Developments
- 27 November 2025: The FSB published the 2025 G-SIB list, identifying 29 banks across five buckets using end-2024 data.
- 27 November 2025: The FSB confirmed that bucket-increase requirements from the 2025 list take effect on 1 January 2027, the standard fourteen-month lag from announcement to effective date.
- 2025 publication cycle: The BCBS denominators page published the end-2024 indicator denominators, with the size denominator reaching 111,282 in € billions across the assessment sample.
- November 2025: The complexity category became the largest contributor to bucket-allocation score movements, replacing the cross-jurisdictional activity category that drove the 2023 reshuffle.
- 1 January 2026: G-SIBs identified in the November 2024 list reached the effective date for any bucket increases flowing from that publication, completing the prior fourteen-month compliance lag.
Bucket Movements
- Compared with the 2024 list, 2 banks have moved to a higher bucket: Bank of America and Industrial and Commercial Bank of China have moved from bucket 2 to bucket 3.
- One bank has moved to a lower bucket: Deutsche Bank has moved from bucket 2 to bucket 1.
- The list for 2025 includes 29 G-SIBs, the same banks as in the 2024 list, but with a different allocation of the banks to buckets.
- The changes in the allocation of the banks to buckets largely reflect the effects of changes in the underlying activity of banks, with the complexity category being the largest contributor to score movements.
G-SIB Count Over Time
- The 2023 FSB list included 29 G-SIBs, one less than the 2022 list of 30 banks.
- Cross-jurisdictional activity was the category that drove the 2023 score movements.
- The 2025 list includes 29 G-SIBs, holding the count stable for the third consecutive year.
- The population shed one bank between 2022 and 2023, then held flat at 29 across 2023, 2024, and 2025.
Worth noting: The G-SIB population has stayed at 29 banks across the 2023, 2024 and 2025 lists per FSB publications, even as individual banks have shifted between buckets. Movement in the framework now sits at the bucket level, not the population level.
G-SIBs by Country and Region
- Eight U.S. banks appear on the 2025 list (8 of 29): JPMorgan Chase, Bank of America, Citigroup, Goldman Sachs, Bank of New York Mellon, Morgan Stanley, State Street, and Wells Fargo.
- China contributes five G-SIBs: Industrial and Commercial Bank of China, Agricultural Bank of China, Bank of China, China Construction Bank, and Bank of Communications.
- France contributes four G-SIBs: BNP Paribas, Groupe Crédit Agricole, Groupe BPCE, and Société Générale.
- Japan contributes three G-SIBs: Mitsubishi UFJ FG, Mizuho FG, and Sumitomo Mitsui FG.
- Three U.K. banks appear on the 2025 list: HSBC, Barclays, and Standard Chartered.
| Region | Country | Number of G-SIBs |
|---|---|---|
| Americas | United States | 8 |
| Americas | Canada | 2 |
| Europe | United Kingdom | 3 |
| Europe | France | 4 |
| Europe | Switzerland | 1 |
| Europe | Germany | 1 |
| Europe | Spain | 1 |
| Europe | Netherlands | 1 |
| Asia-Pacific | China | 5 |
| Asia-Pacific | Japan | 3 |
Source: FSB 2025 G-SIB List Annex (P271125.pdf)
The country mix tells a different story from the balance-sheet rankings. Four jurisdictions (the United States, China, France, and the United Kingdom) account for twenty of the 29 banks, with the United States alone supplying more than a quarter of the population. The Visa transaction data tracks the adjacent payment infrastructure that several of these same universal banks operate through.
U.S. G-SIBs
- JPMorgan Chase sits in bucket 4 (2.5% HLA), the only bank globally at that tier in the 2025 list.
- Bank of America and Citigroup sit in bucket 3 (2.0% HLA) in the 2025 list.
- Goldman Sachs sits in bucket 2 (1.5% HLA) alongside eight non-U.S. peers in the 2025 list.
- Bank of New York Mellon, Morgan Stanley, State Street, and Wells Fargo sit in bucket 1 (1.0% HLA) in the 2025 list.
Bank of America’s promotion
Bank of America moved from bucket 2 to bucket 3 in the 2025 list, raising its required HLA capital from 1.5% to 2.0% of risk-weighted assets. The 50-basis-point increase represents the marginal capital cost of crossing the bucket threshold. That added capital is required from 1 January 2027 under the fourteen-month FSB compliance lag.
Chinese G-SIBs
- Industrial and Commercial Bank of China sits in bucket 3 (2.0% HLA) in the 2025 list, up from bucket 2 in the 2024 list.
- Agricultural Bank of China, Bank of China, and China Construction Bank sit in bucket 2 (1.5% HLA) in the 2025 list.
- Bank of Communications sits in bucket 1 (1.0% HLA) in the 2025 list.
- Across the three populated tiers, China’s five G-SIBs collectively carry HLA surcharges ranging from 1.0% to 2.0%.
ICBC’s promotion to bucket 3
ICBC moved from bucket 2 to bucket 3 in the 2025 list, the only Chinese bank to change buckets that year. The change reflects developments in underlying bank activity, with the complexity category being the largest contributor to score movements. ICBC’s promotion shifts the bucket-3 tier from two banks (Citigroup and HSBC, both in 2024) to four banks in the 2025 list, doubling the population at the 2.0% surcharge tier.
European G-SIBs
- HSBC sits in bucket 3 (2.0% HLA) in the 2025 list, alongside Bank of America, Citigroup and ICBC.
- Barclays, BNP Paribas, Groupe Crédit Agricole, and UBS sit in bucket 2 (1.5% HLA) in the 2025 list.
- Deutsche Bank, Groupe BPCE, ING, Santander, Société Générale, and Standard Chartered sit in bucket 1 (1.0% HLA) in the 2025 list.
- In the 2024 list, Deutsche Bank sat in bucket 2 alongside Barclays, BNP Paribas, and Crédit Agricole.
| Bank | Country | 2025 bucket | HLA |
|---|---|---|---|
| HSBC | United Kingdom | 3 | 2.0% |
| Barclays | United Kingdom | 2 | 1.5% |
| BNP Paribas | France | 2 | 1.5% |
| Groupe Crédit Agricole | France | 2 | 1.5% |
| UBS | Switzerland | 2 | 1.5% |
| Deutsche Bank | Germany | 1 | 1.0% |
| Groupe BPCE | France | 1 | 1.0% |
| ING | Netherlands | 1 | 1.0% |
| Santander | Spain | 1 | 1.0% |
| Société Générale | France | 1 | 1.0% |
| Standard Chartered | United Kingdom | 1 | 1.0% |
Source: FSB 2025 List of G-SIBs Annex (P271125.pdf)
Worth noting: Per the FSB 2025 list, Deutsche Bank’s demotion from bucket 2 to bucket 1 reduces its required HLA capital by 50 basis points effective 1 January 2027, running counter to the broader reshuffle in which Bank of America and Industrial and Commercial Bank of China each moved up one bucket.
Capital Surcharge Tiers Explained
- The HLA requirement for the lowest bucket is 1.0% of risk-weighted assets, met with Common Equity Tier 1 capital.
- The HLA requirement for the highest populated bucket is 2.5% of risk-weighted assets, with an initially empty top bucket of 3.5%.
- The bucket thresholds were calibrated using end-2012 data per the BCBS framework.
- In the 2025 list, bucket 4 (2.5%) holds one bank, bucket 3 (2.0%) holds four banks, bucket 2 (1.5%) holds nine banks, and bucket 1 (1.0%) holds fifteen banks.
Why is bucket 5 empty?
The cutoff score and bucket thresholds were calibrated such that the top bucket of 3.5% of risk-weighted assets is initially empty. The design intent is to incentivise G-SIBs against further systemic-risk-score growth: a bank whose score would push it into bucket 5 faces an additional 100-basis-point CET1 surcharge versus bucket 4.
The American Express data sits well outside that frame as a non-G-SIB specialised lender. Scale alone does not determine bucket placement; cross-jurisdictional activity, interconnectedness, and complexity all carry equal weight.
Total Loss-Absorbing Capacity (TLAC) Requirements
- FSB member authorities apply 4 requirements to G-SIBs: a Higher capital buffer, Total Loss-Absorbing Capacity (TLAC), Resolvability, and Higher supervisory expectations.
- The TLAC requirement sits alongside the higher capital buffer as a distinct G-SIB obligation in the FSB framework.
- The four-requirement architecture combines balance-sheet capital (HLA), gone-concern loss-absorbing instruments (TLAC), resolvability planning, and intensified supervision.
| Requirement | What it covers |
|---|---|
| Higher capital buffer | CET1 surcharge above Basel III minimums per bucket (1.0% to 3.5%) |
| Total Loss-Absorbing Capacity (TLAC) | Gone-concern loss-absorbing instruments above regulatory capital |
| Resolvability | Recovery and resolution planning, including cross-border coordination |
| Higher supervisory expectations | Intensified ongoing supervision per home and host authorities |
Source: FSB 2025 List of G-SIBs (P271125 web page)
Why it matters: The four FSB G-SIB requirements work together rather than in isolation. The Higher Loss Absorbency tier from the bucket allocation is the going-concern leg, while TLAC supplies the gone-concern leg, and resolvability planning ensures the framework’s tools can actually be deployed if a G-SIB enters resolution. See SEC and CFTC crypto enforcement data for an adjacent enforcement perimeter where comparable resolvability frameworks are still emerging.
How Are Global Systemically Important Banks Identified?
Basel Committee on Banking Supervision scores each bank in the assessment sample against the five categories of systemic importance (size, cross-jurisdictional activity, interconnectedness, substitutability/financial institution infrastructure and complexity), each weighted at 20%. The current cutoff score is set at 130 basis points, above which a bank is designated a G-SIB.
The mechanistic indicator-based scoring sits alongside the exercise of supervisory judgment, which can place a bank in a bucket despite its score being above or below the relevant threshold. The 2025 list was identified by the FSB in consultation with the BCBS and national authorities and uses end-2024 data.
Conclusion
The FSB’s 2025 list anchors 29 global systemically important banks across four populated buckets, with JPMorgan Chase alone at the 2.5% CET1 surcharge tier. Bank of America and ICBC’s promotions to bucket 3, alongside Deutsche Bank’s demotion to bucket 1, bind capital plans from 1 January 2027 under the FSB’s fourteen-month lag. Basel Committee on Banking Supervision rules anchor the 130-basis-point cutoff, the equal 20% weight across five systemic-importance categories, and the 111,282 (in € billions) end-2024 size denominator.
The G-SIB framework is one of the few regulatory regimes where the announcement-to-effective gap is structural. Treasury teams plan to the 1 January 2027 effective date, not the publication date.