The global standard

The Financial Stability Board finalised the TLAC term sheet in November 2015 to ensure that any global systemically important bank (G-SIB) can be resolved without public support. The standard requires a minimum stock of instruments legally capable of absorbing losses in resolution, calibrated as a percentage of risk-weighted assets and of the leverage exposure.

EU implementation

The EU wrote TLAC into directly applicable law in the 2019 banking package: Article 92a CRR sets the minimum requirement for institutions identified as G-SIIs — 18% of risk-weighted assets and 6.75% of the leverage exposure since 2022 — and Articles 72a–72l define which liabilities are eligible. Unlike MREL, which is set bank by bank, the TLAC minimum is a uniform Pillar 1 requirement.

Relationship with MREL

For EU G-SIIs the two regimes stack: the resolution authority sets MREL at a level at least equal to the TLAC minimum and may add a bank-specific amount on top. For all other banks, only MREL applies.