EBA is currently developing several concepts related to IRB in addition to the recently published consultation from BIS (which introduces capital floors). ESBG is therefore concerned of possible divergent approaches appearing from those different regulations/standards and also from different calendars for implementation. This potential lack of synchronisation concerning the publication of different regula-tions/criteria/standards - currently either in-force or in-study - will impact financial institutions which will have to recalculate the same position under different standards. Finally, we understand that since no concrete proposal has been presented yet, the quantitative impact in terms of capital requirements is quite uncertain and impossible to quantify.