How are sovereign and public-sector exposures risk-weighted, and what are the large exposure limits?
The CRR risk-weight tables for central governments, central banks and public sector entities, equivalent third countries, the large exposure limits and exemptions, and the IFR's own concentration limits.
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Short answer
Under the CRR, exposures to central governments and central banks carry 0%, 20%, 50%, 100%, 100% and 150% for credit quality steps 1–6, and unrated public sector entities carry 20%, 50%, 100%, 100%, 100% and 150%. Firms may copy an equivalent third country's lower weight for its own government in domestic currency. Exposures to one client or connected group may not exceed 25% of Tier 1 capital, or the higher of 25% and €150 million where an institution or investment firm is involved. Most CIFs now apply the IFR's 25% of own funds trading-book limit.
Risk weights and large exposures at a glance
| Point | Rule |
|---|---|
| Central governments and central banks, steps 1–6 | 0%, 20%, 50%, 100%, 100%, 150%; unrated 100% |
| ECB; EU governments and central banks in their own currency | 0% |
| Equivalent third country | Its lower weight for its own government and central bank exposures in domestic currency may be used |
| Public sector entities without their own rating, by the government's step | 20%, 50%, 100%, 100%, 100%, 150%; 100% if the government is unrated; 20% for an original maturity of three months or less |
| Public sector entity with a government guarantee | Exceptionally treated as the government where the guarantee removes any difference in risk |
| CRR large exposure limit | 25% of Tier 1 capital after credit risk mitigation (eligible capital until 28 June 2021) |
| Institution or investment firm involved | Higher of 25% and €150 million, with other members within 25%; if €150 million is above 25%, a firm-set limit of at most 100% of Tier 1 |
| CRR transitional exemptions | Listed low-risk and intra-group exposures, until a post-review act applies and not after 31 December 2028 |
| IFR limit (Class 2, trading book) | 25% of own funds, same €150 million and 100% rule; any excess notified and charged; outer limits of 500% of own funds (excess up to 10 days) and 600% in total (longer excesses) |
Source: Regulation (EU) No 575/2013, Articles 114, 116, 395 and 493(3); Regulation (EU) 2019/2033, Articles 13(2) and 35–41; CySEC Directive DI97-01, paragraph 19.
In the exam
The exam is written from the exam material, which predates the changes below. Expect its answer. If that answer is not among the options and the current rule is, choose the current rule.
Large exposure limit
Exam material: After credit risk mitigation, exposure to one client or connected group may not exceed 25% of eligible capital. Where an institution is involved, the limit is the higher of 25% and €150 million, and never above 100%.
Current law (since 28 June 2021 (Regulation (EU) 2019/876); 26 June 2021 for Class 2 CIFs (Regulation (EU) 2019/2033)): For banks and Class 1-minus CIFs the base is Tier 1 capital, and the €150 million rule covers any institution or investment firm. Class 2 CIFs apply 25% of own funds to trading-book exposures only.
The 25%, €150 million and 100% figures are unchanged; only the capital they are measured against differs.
How are exposures to governments and public bodies weighted?
These tables come from the CRR's standardised approach to credit risk. Today they matter for banks and Class 1-minus CIFs; since 26 June 2021 Class 2 and Class 3 CIFs have used the IFR instead: the highest of fixed overheads, permanent minimum capital and, for Class 2 only, K-factors. The exam material also says CySEC may adjust a requirement based on fixed overheads when a firm's business changes materially; IFR Article 13(2) keeps that power.
A rating from an external credit assessment institution maps to a credit quality step. Central governments and central banks at steps 1 to 6 carry 0%, 20%, 50%, 100%, 100% and 150%, and unrated ones carry 100%. Exposures to the ECB, and to EU governments and central banks in their own currency, carry 0%. The European Commission decides whether a third country's supervisory and regulatory rules are at least equivalent to the EU's. Where an equivalent third country gives its own government or central bank a lower weight for exposures in its domestic currency, EU firms may use the same weight.
Public sector entities without their own rating have their own table, keyed to the step of the central government where they are based: 20%, 50%, 100%, 100%, 100% and 150%. A rated public sector entity is weighted by its own rating instead. Where the government is unrated they carry 100%, and exposures with an original maturity of three months or less carry 20%. Where an equivalent third country weights its own public sector entities using this table, EU firms may do the same; otherwise they apply 100%. Exceptionally, a public sector entity may be treated as its government, regional government or local authority where a guarantee from that body removes any difference in risk. In both tables, only step 6 reaches 150%.
Terms used in this note
- Credit quality step
- One of six grades to which external credit ratings are mapped, each carrying a set risk weight.
- Public sector entity
- A non-commercial public body answerable to a government or local authority, weighted by its own table when unrated.
- Group of connected clients
- Clients linked by control or by economic dependence, so that one's difficulties are likely to spread to the others; treated as one risk.
- K-CON
- The IFR own funds charge for trading-book exposures above the concentration limit.
What are the large exposure limits for CRR firms?
The exam material caps a firm's exposure to any one client or connected group at 25% of eligible capital, measured after credit risk mitigation. Since 28 June 2021 the CRR has measured the limit against Tier 1 capital instead; the mechanics are otherwise unchanged. Where the client is an institution or an investment firm, or a connected group includes one, the limit is the higher of 25% and €150 million, as long as exposures to the group's other members stay within 25%. Where €150 million would exceed 25% of the firm's capital, the firm sets a reasonable limit in its policies to control concentration risk, never above 100%.
Member States may exempt listed exposures until a legal act following the Commission's review enters into force, and not after 31 December 2028. CySEC's list, now in Directive DI97-01 for Class 1-minus CIFs, fully exempts covered bonds; claims on EU regional governments and local authorities weighted at 20%; intra-group exposures within the same consolidated supervision; next-day claims on investment firms that are not in a major trading currency and do not count as own funds; half of certain low-risk documentary credits and undrawn credit facilities (off-balance-sheet items) and, with CySEC's agreement, 80% of certain mutual guarantee scheme guarantees; legally required guarantees on mortgage loans funded by mortgage bonds; and claims on recognised exchanges. The list is limited to low-risk, intra-group and market-infrastructure items.
What concentration limits apply to IFR firms?
Since 26 June 2021 Class 2 CIFs have applied the IFR's concentration rules, which cover trading-book exposures only. The limit is 25% of own funds per client or connected group, or the higher of 25% and €150 million where the counterparty is a credit institution or investment firm, capped at 100% of own funds. A firm that exceeds the limit must notify CySEC and hold extra own funds for the excess (the K-CON factor). While an excess lasts 10 days or less, the exposure may not exceed 500% of own funds, and excesses lasting longer may not add up to more than 600%. Some exposures are excluded outright, such as those to central counterparties and to governments weighted at 0%, and CySEC may exempt others, such as covered bonds and intra-group exposures. These IFR exclusions and exemptions have no 2028 end date.
How to think about it
Read each table by counterparty. Governments start at 0% and public sector entities one notch riskier at 20%. Governments reach 100% at steps 4 and 5 and public sector entities already at step 3; in both tables only step 6 reaches 150%. For large exposures, begin at 25% of the capital base, switch to the higher of 25% and €150 million when an institution or investment firm is involved, and never go above 100%. Then check the regime: Tier 1 capital for CRR firms, own funds and the trading book only for IFR firms.
Common mistakes
Using the government table for public sector entities. Unrated public sector entities have their own table, which starts at 20% and stays at 100% from step 3 to step 5.
Keeping eligible capital as the base. Since 28 June 2021 the CRR limit is 25% of Tier 1 capital; IFR firms measure against own funds.
Reading €150 million as a free allowance. Where it is more than 25% of capital, the firm must set its own reasonable limit, and never above 100%.
Assuming the 2028 end date applies to every CIF. It limits the CRR's transitional exemptions; the IFR's exclusions and exemptions have no end date.
Legal references
- Regulation (EU) No 575/2013 on prudential requirements for credit institutions (CRR), consolidated version of 26 June 2026 (opens in a new tab)
Article 114 (central governments and central banks) · Article 116 (public sector entities) · Article 395 (limits to large exposures) · Article 493(3) (transitional exemptions until 31 December 2028)
- Regulation (EU) 2019/2033 on the prudential requirements of investment firms (IFR), consolidated version of 9 January 2024 (opens in a new tab)
Article 13(2) (adjusting the fixed overheads requirement) · Articles 35–41 (concentration risk; Article 37 limits, Article 38 notification, Article 39 K-CON, Article 41 exclusions and exemptions)
- CySEC Directive DI97-01 of 2021 on the discretions under Regulation (EU) No 575/2013 (R.A.D. 340/2021), Greek text (opens in a new tab)
Paragraph 19 (exemptions from the large exposure limits)
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