There have been inaccurate reports online that gold will be reclassified as Tier 1 HQLA (High Quality Liquid Asset) under Basel III as of July 1, 2025. This information is not correct; no official announcement has been made or is expected on gold gaining HQLA status.
Why is there confusion?
There is a lot of online misinformation about Basel III more broadly. Related to gold specifically, various websites state that gold will be reclassified as Tier 1 HQLA on July 1. Let’s pause here. Tier 1 refers to capital rules that were written in the original Basel Accord in July 1988 which became known as Basel 1. HQLA is a function within the liquidity rules of LCR and NSFR which were first written into Basel 3 and implemented by Basel on January 1, 2019. People are getting mixed up between capital rules and liquidity rules. LBMA is advocating for gold to be reclassified as Level 1 HQLA – again note this isn’t Tier 1 because HQLA relates to a liquidity rule.
A lesser number of articles say that gold is due to become Level 1 HQLA but again this isn’t correct, as stated above no announcement has been or is expected.
Gold is already a Tier 1 asset under the Basel Capital Accords meaning that it has a 0% risk weight. This is true for all three Basel Accords. The rule states that gold held in a bank’s own vault is deemed as a Tier 1 asset with a zero-risk weighting. Nothing has changed since the original Basel I Accord was created in 1988.
Gold is not due to be reclassified as a Level 1 HQLA – if it were, we and the WGC would be the first to shout about it. LBMA continues to advocate with the central bank and prudential regulatory community that gold meets all criteria to warrant HQLA status. The latest research on this, by Professor Dirk Baur et all (2024) (SSRN), argues that gold meets the characteristics of a Level 1 HQLA, namely low bid-ask spreads, high volumes, relatively low volatility and negative correlation with risky assets during stress periods. The quantitative analysis shows that gold is highly liquid and, indeed, among the most liquid assets across a sample of top tier government bonds both on a long term and during a financial stress event. Gold generally performs similarly to a 30-year US Treasury bond. Adding gold to a HQLA portfolio enhances its resilience. The paper also includes a revised liquidity test that was first used in 2013 by the European Banking Authority. Gold is remarkably liquid with an Amihud measure of 0.102 compared with US Treasury bonds with Amihud measure estimates ranging from 0.055 (3-5 year bonds) to 1.321 (10-20 year bonds). A further SUERF Policy Brief, written by David Gornall (Senior Advisor, LBMA, and LBMA Chairman June 2011 to July 2014) and Edel Tully (Director of Financial Services, LBMA), makes a similar argument for gold as a Level 1 HQLA.
What are the different weightings for gold currently within Basel III?
There is often some confusion over the status of gold within Basel III due to the different weightings and ratings that are used within the rules of the 1,600-odd page rulebook.
There are three percentages relating to gold: 0%, 20% and 85%:
0%
Gold benefits from a 0% rate for Bank Tier 1 capital. Claims secured by allocated gold also have a 0% risk weight under the Risk Weighted Asset credit risk rules. This is the same as for cash and was the same treatment used in the first version of Basel.
20%
The current Basel-based prudential regulatory framework allows clearing houses the ability to accept gold as a collateral for margin payments with a haircut of 20%.
85%
As gold sits outside of the High-Quality Liquid Asset list, it suffers from an 85% required stable funding (RSF) factor and a 0% available stable funding factor under the Net Stable Funding Ratio (NSFR) rules. This is the same RSF factor as corn or lead and was only introduced with the last version of the rules in Basel III.
The above also demonstrates the somewhat inconsistent treatment of prudential regulation of gold, in particular when comparing its treatment under credit risk and eligibility as collateral versus its treatment for liquidity coverage purposes.
What are the timelines?
Most jurisdictions follow Basel implementation timetables, apart from the EU, UK and the US. The final Basel III rules, also known as Basel 3.1 and Basel III endgame, have been delayed consistently across these three major jurisdictions since the BCBS first proposed Basel 3 reforms following the global financial crisis. The EU has delayed some of the key reforms to January 2026. The UK has delayed implementation to 2027 and in the US, given the current political landscape which favours less regulation and heavy lobbying, the timetable is unclear.
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