加强AT1的持续经营作用：选择和权衡

No32 Strengthening the going-concern roleof AT1: options and trade-offs Rodrigo Coelho, Yvan Lengwiler, Kumar Rishabh and RastkoVrbaski June 2026 FSI Briefs are written by staff members of the Financial Stability Institute (FSI) of the Bank for InternationalSettlements (BIS), sometimes in cooperation with other experts. They are short notes on regulatory andsupervisory subjects of topical interest and are technical in character. The views expressed in thispublication are those of the authors and do not necessarily reflect the views of the BIS, its membercentral banks or the Basel-based standard-setting bodies. Authorised by the Chair of the FSI, Fernando Restoy. This publication is available on the BIS website (www.bis.org). To contact the BIS Global Media and PublicRelationsteam,pleaseemailmedia@bis.org.Youcansignupforemailalertsatwww.bis.org/emailalerts.htm. ©Bank for International Settlements 2026. All rights reserved. Brief excerpts may be reproduced ortranslated provided the source is stated. Strengthening the going-concern role of AT1: options andtrade-offs1 Highlights •Additional Tier 1 (AT1) instruments are designed to operate as going-concern capital. In instanceswhere the issuer reaches the point of non-viability, these instruments also support an orderlyresolution of a gone concern.•Nonetheless, in practice, the effectiveness of AT1 Instruments in fulfilling their primary role asgoing-concern capital is undermined by low trigger thresholds, the discretionary nature ofactivation and insufficient incentives for recapitalisation.•Restoring this function rests on three elements: (i) sufficiently dilutive, variable and market-linkedconversion as a principal loss-absorption mechanism; (ii) elimination of writedown and ofdiscretionary going-concern triggers; and (iii) Common Equity Tier 1 (CET1)-linked triggers sethigh enough to support recovery.•Such reforms have to be weighed against potential adverse implications for banks’ funding costs,buffer usability and resolution funding. 1.Introduction Key to making the banking sector more resilient is ensuring that losses on bank balance sheets areabsorbed early enough. This principle led regulators in the aftermath of the Great Financial Crisis tocreate Additional Tier 1 (AT1) capital – a class of debt-like instruments that can help cushion shocks, likeequity.2The Basel Framework classifies AT1 as going-concern capital: instruments designed to absorblosses while the bank remains viable and operating. The objective is to restore the bank’s financial healthbefore it reaches the point where resolution becomes necessary. AT1 instruments absorb losses through two channels. First, an automatic trigger, typically linkedto the bank’s Common Equity Tier 1 (CET1) ratio falling below a predefined threshold, results in the bankwriting down or converting the instrument into equity, immediately improving the bank’s CET1 capitalposition. Second, bank management has broad discretion to cancel interest (coupon) payments toconserve capital. Beyond these going-concern mechanisms, AT1 instruments also carry a non-viabilityclause that requires authorities to write down or convert them when the bank is no longer viable. Thisgives AT1 a secondary, gone-concern function, making it available to support resolution alongside itsprimary role in recovery.3 In practice, however, AT1’s going-concern function has not materialised. Current designfeatures mean that AT1 instruments rarely absorb losses while a bank is still viable, and markets do notprice them as if they will. The instruments have instead functioned primarily as gone-concern capital,activated only at or near the point of failure.4 The writedown of Credit Suisse’s AT1 instruments in March 2023 demonstrated this. Indeed, itwas only once the Swiss supervisory authority declared a viability event that Credit Suisse AT1instruments were written down. Prior to that, they did nothing to contribute to the firm’s recovery efforts,while continuing to distribute coupons. Moreover, the sharp repricing in AT1 instruments issued by otherbanks following the Credit Suisse event indicates that investors had not priced key state contingencies,in particular viability events and supervisory discretion (Di Stefano et al (2026)). Unsurprisingly, AT1instruments have since faced heightened scrutiny, echoing previously voiced scepticism.5 The gap between design and function creates uncertainty rather than stability, an outcome thatis not viable from a prudential perspective. Against that background, policymakers are left with twobroad options. The first is to phase out AT1 entirely as regulatory capital. The Australian PrudentialRegulation Authority (APRA) has taken this path, concluding that AT1 does not fulfil a stabilising functionin a crisis due to the complexities of using it and the risk of causing contagion.6The second option is toreform AT1 so that it functions as originally intended. The case for reform rests on whether a wel