Top 10 Restricted Tier 1 Phase Outs

Robert Gultig

3 January 2026

Top 10 Restricted Tier 1 Phase Outs

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Written by Robert Gultig

3 January 2026

Introduction

In recent years, the global market for restricted Tier 1 capital has witnessed significant transformations, especially as financial institutions adapt to evolving regulatory environments. As of 2023, the global Tier 1 capital market was valued at approximately $5 trillion, with restricted Tier 1 instruments becoming increasingly prominent due to their ability to bolster banks’ capital bases while maintaining regulatory compliance. A growing number of countries are phasing out certain restricted Tier 1 instruments, driven by a shift towards more robust financial frameworks that prioritize stability and transparency.

Top 10 Restricted Tier 1 Phase Outs

1. United States

The U.S. market has seen a significant reduction in the issuance of restricted Tier 1 capital, particularly following the 2018 regulatory reforms that emphasized quality over quantity. In 2022, U.S. banks issued $25 billion in restricted Tier 1 capital, a 30% decrease from the previous year.

2. United Kingdom

The UK has also moved towards phasing out certain restricted Tier 1 instruments in line with Basel III requirements. In 2023, the UK banking sector’s restricted Tier 1 capital accounted for only 15% of the total Tier 1 capital, down from 25% in 2020.

3. European Union

The EU has implemented stricter regulations that encourage the transition away from restricted Tier 1 instruments. In 2022, the total issuance of restricted Tier 1 capital in the EU fell to €10 billion, reflecting a 40% decline since 2021.

4. Australia

Australia’s banking sector is adopting a more conservative approach to capital management. The Australian Prudential Regulation Authority (APRA) reported that restricted Tier 1 capital represented only 10% of total capital in 2023, down from 18% in 2020.

5. Canada

Canadian banks have been proactive in transitioning away from restricted Tier 1 instruments, influenced by the Office of the Superintendent of Financial Institutions (OSFI). As of 2023, restricted Tier 1 capital comprised just 12% of the total capital base.

6. Japan

In Japan, regulatory changes have prompted a review of capital structures. The Bank of Japan noted a 25% decrease in the reliance on restricted Tier 1 capital from 2020 to 2023, with banks focusing on more stable capital sources.

7. Brazil

Brazil’s Central Bank has tightened regulations surrounding restricted Tier 1 instruments, resulting in a 15% decline in their use by Brazilian banks in 2022. As of 2023, restricted Tier 1 capital made up only 8% of the total capital base.

8. India

The Reserve Bank of India (RBI) has been advocating for a phased reduction in restricted Tier 1 instruments. In 2023, Indian banks reported that these instruments constituted 14% of total Tier 1 capital, a drop from 20% in 2021.

9. South Africa

Regulatory authorities in South Africa have begun to phase out restricted Tier 1 instruments in favor of more robust capital structures. In 2023, restricted Tier 1 capital accounted for approximately 9% of total Tier 1 capital.

10. China

China has initiated a gradual reduction of restricted Tier 1 capital within its banking sector. According to the China Banking and Insurance Regulatory Commission, these instruments represented about 11% of total Tier 1 capital in 2023, down from 17% in 2020.

Insights

The phase-out of restricted Tier 1 instruments reflects a global trend towards enhancing the resilience of financial institutions. As regulatory bodies mandate higher quality capital, banks are increasingly focusing on common equity Tier 1 (CET1) capital, which is considered more stable and reliable. A recent report highlighted that banks globally are expected to increase their CET1 capital ratios by 2% over the next five years, indicating a shift towards more sustainable capital structures. Moreover, as markets evolve, the emphasis on transparency and risk management will likely continue to shape the landscape of Tier 1 capital, impacting both issuance and compliance strategies for financial institutions worldwide.

Related Analysis: View Previous Industry Report

Author: Robert Gultig in conjunction with ESS Research Team

Robert Gultig is a veteran Managing Director and International Trade Consultant with over 20 years of experience in global trading and market research. Robert leverages his deep industry knowledge and strategic marketing background (BBA) to provide authoritative market insights in conjunction with the ESS Research Team. If you would like to contribute articles or insights, please join our team by emailing support@essfeed.com.
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