FRTB implementation: an uneven playing field

Market risk functions are approaching Fundamental Review of the Trading Book (FRTB) implementation against an increasingly fragmented regulatory backdrop. Diverging rules across jurisdictions, difficult decisions over the internal models approach (IMA) versus the standardised approach, and rising technology and data demands are forcing banks to reassess the economics as well as the practicalities of compliance.

This briefing from the Risk.net Market Risk Leaders’ Network held in London in July 2026 captures insights from senior market risk professionals on the realities of implementing FRTB, from capital and business impacts to data quality, model complexity and the challenges of operating different regulatory frameworks across global businesses.

Among the takeaways:

• The IMA is increasingly an economic decision: banks are weighing potential capital benefits against substantial technology, compute and ongoing operational costs
• Regulatory divergence is reshaping the playing field: different approaches across the US, UK, European Union and other jurisdictions can influence capital outcomes, competitiveness and where individual trades are booked
• Complexity can undermine risk management benefits: prescriptive regulatory measures do not always align neatly with the economic risks desks actually manage
• The cost challenge extends beyond implementation: running multiple approaches and frameworks in parallel can create a significant and lasting resource burden
• Data quality remains fundamental: look-through requirements and complex calculations magnify problems with missing, late or inaccurate data, making ownership and lineage critical
• Artificial intelligence offers opportunities – with limits: AI can support anomaly detection, data lineage and automation, but strong governance and human verification remain essential.

Download the report to explore how market risk leaders in London are navigating FRTB strategy, capital impacts and the practical challenges of implementation.