Financial regulation is increasingly assessedby 1. its contribution to stability and consumer protection,2. by its effect on investment, innovation, market development and geopolitical resilience.
This has created renewed interest in competitive regulatory rationalisation: the systematic removal of duplication, inconsistency, unnecessary complexity and disproportionate requirements without weakening essential prudential, conduct, financial-crime or operational-resilience safeguards.
The challenge is especially significant in a world of geopolitical fragmentation, sanctions, technological rivalry, cross-border data restrictions, supply-chain concentration and competing payment infrastructures. Financial regulation is now is part of a jurisdiction’s economic infrastructure and attractiveness. Rationalisation must therefore avoid both a race to the bottom and a race to complexity.
Regulation as Economic and Strategic Infrastructure
The post-global-financial-crisis regulatory framework was constructed principally to repair weaknesses in bank capital, liquidity, governance, resolution planning, market infrastructure and supervisory intensity. Those reforms materially strengthened the resilience of the financial system. Yet successive layers of prudential, conduct, resolution, sustainability, financial-crime, data, cyber and operational requirements have also created complex interactions that may not always increase fin sector performance commensurate with their cost.
The policy question is therefore changing. It is no longer simply whether a particular rule is justified in isolation. Regulators must increasingly ask whether the combined regulatory architecture remains coherent, proportionate and capable of supporting a competitive economy.
This question has become more urgent because the global financial system operates in a fundamentally different geopolitical environment. Strategic rivalry, sanctions, investment screening, restrictions on technology transfers, competing data-governance regimes and concerns over payment-system dependence are reshaping capital flows and financial intermediation. The International Monetary Fund has identified several channels through which geopolitical tensions can produce financial fragmentation, including capital-flow reversals, changes in bank funding costs, disruption of cross-border payments and reduced opportunities for international risk diversification (IMF, 2023).
Regulatory policy has consequently acquired a strategic dimension. Licensing decisions influence where financial firms locate. Capital and liquidity rules influence where financial groups deploy resources. Data and outsourcing requirements influence where technology infrastructure is built. Market-access arrangements influence which jurisdictions become regional hubs. Sanctions, anti-money-laundering requirements and beneficial-ownership standards affect access to correspondent banking and international payment networks.
Competitive regulatory rationalisation must respond to this environment without turning financial supervision into disguised industrial policy. Its objective should be to create a framework that is credible, efficient, internationally recognised and strategically resilient.
Rationalisation, Not Deregulation
Regulatory rationalisation is sometimes presented as a choice between strict regulation and light-touch regulation. This is misleading. Rationalisation concerns the design, structure and implementation of regulation rather than simply the quantity of rules.
A rationalisation exercise may remove a reporting return that duplicates information already available to the supervisor. It may consolidate overlapping outsourcing requirements. It may replace several licensing categories with a modular permission structure. It may apply simplified prudential calculations to small, non-complex institutions while maintaining more intensive requirements for systemically important firms. It may clarify ambiguous rules or replace repetitive transaction-level approvals with properly controlled notification arrangements.
None of these changes necessarily lowers regulatory standards. Indeed, simplification can strengthen regulation when it allows institutions and supervisors to focus on material risks rather than administrative formality.
This distinction is now explicit in official practice. The Basel Committee’s proportionality framework supports proportionate regulatory and supervisory approaches while expressly cautioning that proportionality should not undermine financial stability or the safety of financial institutions. The revised Basel Core Principles similarly embed proportionality throughout banking supervision, permitting supervisory expectations to reflect a bank’s risk profile, systemic importance and the characteristics of the financial system in which it operates (BCBS, 2022, 2024). The first stated principle of the European Central Bank’s High-Level Task Force on Simplification is that resilience must be maintained, and that simplification is not deregulation (ECB, 2025).
A sound rationalisation programme should therefore distinguish among four different actions:
Repeal is appropriate when a requirement has become obsolete or no longer addresses a material risk.
Consolidation is appropriate when several requirements pursue substantially the same objective.
Simplification is appropriate when an objective remains valid but can be achieved through a less complex method.
Recalibration is appropriate when the requirement remains necessary but its intensity, frequency or scope is disproportionate to the underlying risk.
This taxonomy prevents rationalisation from becoming an indiscriminate rule-reduction exercise. It also imposes an evidential discipline: each action must be justified against the risk the requirement was intended to address, not against an aggregate target for the number of rules removed.
Regulatory Competitiveness as Institutional Quality
A jurisdiction is not necessarily attractive because its rules are weak. Banks, institutional investors, insurers, asset managers and fintech firms also value legal certainty, enforceable contracts, supervisory competence, predictable authorisation processes, credible dispute resolution and international recognition.
Regulatory competitiveness should therefore be understood as a form of institutional quality. Its principal elements are:
- clarity about the regulatory perimeter;
- proportionality between requirements and risks;
- predictable interpretation and enforcement;
- timely licensing and supervisory decisions;
- consistency across similar products and activities;
- compatibility with international standards;
- efficient digital interaction with regulators; and
- confidence that weak or non-compliant firms will be addressed promptly.
A lightly regulated jurisdiction may initially attract opportunistic firms, but it can lose correspondent banking relationships, equivalence recognition and institutional investment if its supervisory credibility is questioned. Conversely, a jurisdiction with technically strong but highly duplicative or unpredictable regulation may discourage legitimate business without materially reducing risk.
The optimal framework is consequently neither the fewest rules nor the most rules. It is the smallest coherent set of requirements capable of producing the intended regulatory outcomes.
International Experience
Basel : proportionality within minimum standards
Basel standards provide the most important foundation for rationalisation in banking. The Basel framework was designed primarily for internationally active banks, but the Basel Committee recognises that domestic implementation must accommodate different banking systems and institutions.
The 2022 high-level considerations encourage authorities to articulate the objectives of proportionality, develop transparent eligibility criteria, assess potential competitive effects and ensure that simplified requirements do not create material regulatory arbitrage (BCBS, 2022). The Core Principles, revised in April 2024, reinforce the concept by linking supervisory intensity to systemic importance and risk profile (BCBS, 2024).
This suggests that proportionality should not be based exclusively on asset size. A relatively small institution can have a high-risk funding model, substantial cross-border exposures, concentrated digital-asset activity or critical payment-system functions. Conversely, a larger institution with a simple domestic business model may not require every element of a framework designed for a complex international group.
A credible proportionality regime should therefore consider size, complexity, interconnectedness, substitutability, business model, funding structure, cross-border activity and potential harm to customers.
The European Union: simplification after resilience
The European Union provides the most significant contemporary example, because it is attempting to preserve the resilience achieved since the financial crisis while addressing fragmentation and complexity.
The European Central Bank’s Governing Council established a High-Level Task Force on Simplification in March 2025, chaired by Vice-President Luis de Guindos. The Task Force’s report, published on 11 December 2025 and endorsed by the Governing Council, sets out recommendations across the regulatory, supervisory and reporting frameworks. Its recommendations are anchored in four principles: resilience must be maintained and simplification is not deregulation; effectiveness in meeting prudential objectives must be preserved; European harmonisation and financial integration should be fostered; and international cooperation, including full and timely implementation of Basel III, should be upheld (ECB, 2025). The reporting recommendations are of particular practical interest, encompassing data sharing among European authorities, an integrated European reporting system, a materiality-based tolerance for reporting errors, an inventory of reporting requirements imposed on banks and periodic review of their continuing relevance.
The European Commission’s Communication on the Competitiveness of the Banking Sector and the Single Market in Banking, adopted on 17 July 2026, identifies three interconnected challenges: continuing fragmentation along national borders; implementation of international standards in a manner that could better reflect European specificities and proportionality; and aspects of the regulatory framework that are unduly complex and burdensome (European Commission, 2026). The Communication nevertheless treats resilience as a precondition for sustainable competitiveness rather than an obstacle to it. It is not itself a legislative proposal; it signals a reform agenda for which formal proposals are anticipated in 2027. On reporting, it supports integrated prudential, statistical and resolution reporting, further mandates for the European Banking Authority on proportionality and automation, rationalisation of accumulated guidance and questions-and-answers material, and reduction of duplicative national and EU reporting. Measures already implemented, together with further steps proposed for 2026, are expected to reduce the number of data points in EU reporting frameworks very substantially.
The EU experience shows why rationalisation must examine interactions among rules. Complexity may arise not from one regulation, but from the accumulation of capital buffers, national discretions, resolution requirements, reporting definitions, soft-law instruments and divergent supervisory practices. It is notable that both the ECB and the Commission identify the overlap between microprudential, macroprudential and resolution requirements as a distinct source of burden, separate from the content of any individual rule.
At the same time, the EU’s Digital Operational Resilience Act demonstrates the potential benefit of cross-sector harmonisation. Instead of allowing entirely separate ICT-risk frameworks for banks, insurers, investment firms, payment institutions and other entities, DORA establishes a more uniform financial-sector approach to ICT risk, incident reporting, resilience testing and third-party oversight. Harmonisation of this kind may initially require significant implementation effort, but it can reduce longer-term fragmentation (European Parliament & Council of the European Union, 2022).
The United Kingdom: competitiveness within statutory safeguards
The United Kingdom has given the Financial Conduct Authority and Prudential Regulation Authority secondary objectives relating to the medium- to long-term growth and international competitiveness of the UK economy. These objectives remain subordinate to their primary regulatory mandates and are subject to alignment with relevant international standards under the Financial Services and Markets Act 2023.
The Prudential Regulation Authority’s Strong and Simple framework illustrates how this can operate in practice. The framework creates simplified but resilient prudential requirements for eligible Small Domestic Deposit Takers (SDDTs). It was delivered in two phases: liquidity and disclosure simplifications were finalised first, and the simplified capital regime followed, consulted on in 2024, published in near-final form in October 2025 and finalised on 20 January 2026 (PRA, 2026). The capital regime simplifies every element of the capital stack. Pillar 2A methodologies are streamlined through a dedicated statement of policy for SDDTs; the countercyclical capital buffer and capital conservation buffer are replaced, for these firms, by a single, more constant and predictable capital buffer.
The significance of the UK model lies in its attempt to create a separate, coherent regime rather than merely providing ad hoc exemptions from a complex framework. A simplified regime is more usable when eligibility, entry, exit and transition arrangements are clear. Without those elements, firms may be uncertain whether growth, acquisition or business-model change will suddenly expose them to a substantially different regulatory structure. The framework’s durability will depend on whether the simplification survives supervisory practice over time; industry commentary has already identified the risk that firms and supervisors gradually reintroduce complexity through voluntary adoption of more sophisticated methods presented as good practice.
The United States: categorical tailoring and material-risk supervision
The United States has used categorical tailoring to differentiate requirements for large banking organisations. The Federal Reserve’s 2019 framework categorised firms using asset size together with indicators such as cross-jurisdictional activity, non-bank assets, off-balance-sheet exposure and reliance on short-term wholesale funding, with more stringent standards applying as risk and complexity increase (Board of Governors of the Federal Reserve System, 2019).
The Financial Stability Oversight Council’s 2025 Annual Report, approved on 11 December 2025, supports current efforts to simplify and modernise regulatory capital standards, to focus bank supervision on material financial risks, and to apply tailoring proportionately, including through reduced compliance burden for community banks. It couples this with a call for cost-benefit analysis of significant regulations, while continuing to recognise the importance of an appropriately regulated and supervised banking system for financial stability (FSOC, 2025). The report reflects a broader repositioning of the Council towards economic growth as an explicit consideration in financial-stability assessment — a shift that itself illustrates how rationalisation agendas can carry policy direction beyond technical simplification.
The US experience demonstrates both the value and the difficulty of categorical thresholds. Categories can improve clarity, but they can also become blunt if risk grows rapidly within an institution that remains below a formal threshold — a lesson reinforced by the March 2023 banking turmoil. Quantitative categories therefore need to be supplemented by supervisory judgement and mechanisms for responding to changing risk profiles.
Asian and GCC financial centres: innovation pathways
Singapore, Hong Kong and several Gulf financial centres have used regulatory sandboxes and innovation programmes to reduce uncertainty around new business models.
The Monetary Authority of Singapore’s framework is instructive because it is tiered rather than uniform. The bespoke FinTech Regulatory Sandbox, launched in 2016, permits controlled experimentation in the production environment within a defined space and duration, subject to safeguards designed to contain the consequences of failure. It was supplemented by Sandbox Express in 2019, offering faster market testing in pre-defined environments, and by Sandbox Plus from January 2022, which widened eligibility beyond first movers to early adopters of technology innovation and combined sandbox entry with funding support (MAS, 2022).
The Hong Kong Monetary Authority’s Fintech Promotion Blueprint, published on 3 February 2026 under the “Fintech 2030” strategy, similarly relies on supervised testing environments — including an enhanced generative artificial-intelligence sandbox and a supervisory incubator for distributed-ledger technology — as instruments for moving the banking sector from broad adoption of digital tools towards deeper integration of advanced technology (HKMA, 2026).
Areas for Rationalisation
Licensing and the regulatory perimeter
Financial-sector licensing frameworks frequently evolve through incremental additions. New categories are introduced for payment firms, crowdfunding platforms, digital-asset providers, open-finance intermediaries, finance companies and specialised investment businesses. Over time, several categories may cover similar risks while imposing different capital, governance or conduct requirements.
Rationalisation should begin with an activity-and-risk map. Each regulated activity should be connected to the risks it creates: safeguarding risk, credit risk, market risk, liquidity risk, operational risk, financial-crime risk, customer-harm risk or systemic risk. Licensing requirements should then be constructed from modular permissions rather than institutional labels wherever feasible.
This can reduce situations in which economically similar activities are regulated differently merely because one is undertaken by a bank and another by a fintech or non-bank institution. International recommendations for crypto-asset activities similarly support comprehensive and consistent regulation based on functions and risks while allowing proportional domestic implementation (FSB, 2023a).
Modular licensing does not mean that all entities should be regulated identically. Deposit-taking, for example, creates risks that do not arise in every payment or technology business. The objective is consistent treatment of the same risk, not identical treatment of different institutions.
Rulebook architecture
Many regulatory systems contain statutes, regulations, rulebooks, circulars, frequently asked questions, supervisory statements, policy papers and informal interpretations. The cumulative framework can become difficult to navigate, particularly when older instruments remain technically in force. The EU’s own review has identified accumulated guidance and questions-and-answers material as a rationalisation target in its own right.
A rationalised rulebook should establish a clear hierarchy:
- legislation should define mandates and powers;
- binding regulations should establish core obligations;
- rulebooks should provide enforceable requirements;
- guidance should explain acceptable methods without quietly creating new binding duties; and
- supervisory communications should address implementation without contradicting higher-level instruments.
Every requirement should identify its purpose, scope, legal status, commencement date and relationship to other rules. Superseded material should be archived rather than left within the active framework.
Machine-readable tagging can further improve accessibility. Requirements can be tagged by institution type, activity, risk, reporting frequency and applicable transition period. Firms should be able to determine which provisions apply to them without manually searching through multiple volumes.
Regulatory reporting
Reporting is often the area with the greatest potential for efficiency. The same underlying data may be submitted under different definitions to prudential, statistical, resolution, deposit-insurance, conduct and financial-crime authorities.
The correct objective is not simply to reduce the number of returns. It is to create a report-once, use-many-times architecture. This requires common data definitions, unique identifiers, consistent reference dates, application programming interfaces and clear governance over data quality and access. The European agenda is explicitly framed in these terms, combining an integrated reporting system with reduced resubmission and a materiality-based tolerance for errors — a recognition that the burden of reporting arises as much from correction cycles and definitional divergence as from the volume of returns.
Removing a return without ensuring that supervisors retain necessary information would weaken oversight. Conversely, automating a poorly designed return merely digitises inefficiency. Genuine rationalisation asks which regulatory decisions depend on the data, whether another authority already holds it and whether the data can be derived from more granular submissions.
Integrated reporting can also improve geopolitical resilience. When authorities have coherent, timely data, they can better assess sanctions exposures, cross-border funding concentrations, critical-service dependencies and emerging payment disruptions.
Proportionality
Proportionality should apply not only to prudential ratios but also to governance, disclosure, recovery planning, stress testing, outsourcing reviews and supervisory engagement.
However, a proportionate framework requires a credible escalation mechanism. Firms that grow, become more complex or enter higher-risk businesses should move into enhanced requirements. Supervisors should also retain the ability to apply additional requirements where an institution presents risks not adequately captured by its formal category.
The eligibility test should therefore combine quantitative thresholds with qualitative conditions. Those conditions may include domestic focus, limited trading activity, absence of complex group structures, low cross-border dependence, straightforward funding and limited systemic substitutability.
Proportionality should reduce unnecessary complexity, not create a lower standard of governance. A small institution still requires competent management, effective risk controls and accurate financial information.
Supervisory processes
Regulatory burden is generated not only by rules but also by the manner in which supervision is conducted. Repetitive information requests, unclear examination scope, multiple reviews of the same issue and delays in regulatory decisions can be as costly as formal requirements. This is why the European simplification agenda extends beyond the rulebook to the supervisory review process, internal-model decisions, stress testing and on-site inspections.
Supervisory rationalisation should include risk-based examination planning, coordinated requests, materiality thresholds and internal decision timelines. Matters that can be handled through notification should not automatically require prior approval. Low-risk applications should be triaged differently from complex changes in control or new banking licences.
Service standards should be published for authorisations and material approvals, but speed should not be pursued by lowering evidential requirements. A better approach is to identify incomplete applications promptly, maintain structured engagement and distinguish time spent by the regulator from time spent awaiting information from the applicant.
Regulators should also measure the effectiveness of supervision. The number of findings or enforcement actions is not, by itself, a reliable indicator of quality. More useful measures include the timeliness with which material risks are identified, the durability of remediation, the reduction of repeated findings and the ability to distinguish serious weaknesses from technical non-compliance.
Technology, Outsourcing and Strategic Concentration
Cloud services, artificial intelligence, distributed ledgers and shared technology platforms create substantial efficiency benefits, but they can also concentrate critical financial functions in a small number of providers. In geopolitical terms, these dependencies may be affected by sanctions, export controls, jurisdictional conflicts, cyber operations or legal restrictions on access to data.
This is an area where regulatory rationalisation should mean greater convergence rather than fewer safeguards. Banks, insurers, payment institutions and investment firms should not be subject to entirely incompatible third-party-risk frameworks where the underlying technology and concentration risks are similar.
The FSB’s third-party-risk toolkit was designed partly to reduce fragmentation across jurisdictions and financial sectors while strengthening the ability of institutions and authorities to identify and manage critical dependencies (FSB, 2023b). The Basel operational-resilience principles similarly require banks to map the people, processes, technology, data, facilities and third parties needed to deliver critical operations through disruption (BCBS, 2021).
A rational framework should therefore focus on outcomes: identification of critical services, due diligence, concentration assessment, access and audit rights, resilience testing, incident notification, substitutability and exit planning. Regulators should avoid prescribing different contractual wording for every sector unless the differences reflect a genuine risk.
Financial Crime, Sanctions and De-Risking
Financial-crime requirements are especially sensitive in a geopolitical environment. Sanctions change rapidly, ownership structures can be opaque and financial institutions may face conflicting legal obligations across jurisdictions.
Rationalisation in this area should not mean reducing scrutiny of high-risk customers or transactions. Instead, it should mean replacing mechanical, universal controls with better risk differentiation.
The Financial Action Task Force’s risk-based approach requires countries, supervisors and institutions to identify and understand money-laundering and terrorist-financing risks and apply mitigation proportionate to those risks. Enhanced measures should be used for higher-risk situations, while simplified measures may be appropriate where risks are demonstrably lower. FATF also encourages supervisors to move beyond uniform, checklist-based examination towards risk-based supervision (FATF, 2014, 2021).
This approach can reduce indiscriminate de-risking. When every customer from a particular country, sector or business model is treated identically, institutions may terminate relationships rather than undertake differentiated assessment. That can push legitimate activity outside regulated channels and weaken financial inclusion.
Authorities should rationalise duplicative customer-information requirements, improve access to reliable beneficial-ownership information and facilitate lawful information sharing. However, sanctions compliance and national-security restrictions should be distinguished clearly from ordinary AML risk. Combining them indiscriminately can produce unclear responsibilities and inconsistent decisions.
The Geopolitical Guardrails
Competitive rationalisation requires explicit guardrails.
First, prudential resilience must remain a non-negotiable foundation. Weakly capitalised or poorly governed financial institutions do not create sustainable competitiveness. They create contingent liabilities for depositors, investors and governments.
Second, international standards should remain the baseline, particularly for internationally active or systemically important firms. Jurisdictions may tailor implementation, but persistent material divergence can undermine equivalence, supervisory cooperation and market access.
Third, national-security objectives should be transparent. Restrictions motivated by sanctions, strategic technology, foreign ownership or data sovereignty should be identified as such rather than embedded indirectly in opaque supervisory expectations.
Fourth, cross-border cooperation must be preserved. Geopolitical rivalry increases the importance of supervisory colleges, crisis-management groups, information-sharing arrangements and coordinated oversight of financial market infrastructures.
Fifth, rationalisation should not transfer risk outside the regulatory perimeter. If requirements are reduced for banks while economically identical risks grow in non-bank or digital channels, the apparent reduction in burden may merely relocate systemic risk.
Sixth, consumer protection should be treated as part of competitiveness. Trust supports market participation. Simplifying disclosures or suitability processes is defensible when it improves customer understanding, not when it conceals risk or removes meaningful protection.
Implications for International Financial Centres and Smaller Open Economies
Smaller open economies face a particular challenge. They cannot rely exclusively on the scale of their domestic market, yet they must maintain international confidence to attract banks, fintech companies, asset managers, family offices and investment platforms.
Their competitive advantage is therefore more likely to come from regulatory precision and responsiveness than from lower standards. This includes clearly defined licensing categories, timely decisions, experienced supervisors, reliable courts, strong financial-crime controls and compatibility with international norms.
Such jurisdictions should be cautious about importing every detailed rule developed for much larger markets. International standards should be implemented faithfully, but domestic frameworks should reflect the structure, complexity and risk profile of the local financial system. The UK’s decision to construct a separate coherent regime for small domestic firms, rather than to accumulate exemptions from a framework designed for internationally active banks, is directly relevant to jurisdictions whose licensee population is dominated by small and mid-sized institutions.
The strategic objective should be to create a jurisdiction in which responsible firms can understand the requirements, receive decisions within reasonable periods, deploy technology safely and operate across borders without encountering avoidable regulatory inconsistencies.
References
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