AWG monitors, and assess the effect of, capital requirements on aircraft financing. It follows a data-driven approach centered on the analysis of loss given default in aircraft backed transactions.
AWG work on Basel
That work extends to assessment of Basel III/IV, produced by the Basel Committee on Banking Supervision (BCBS).
AWG submitted documents dated 10 March 2016, 21 June 2016, and 14 October 2016 explaining then current and historical LGDs for aircraft-backed loans (extremely low) and the effects of the current proposals (substantial increase in required capital). AWG has stated, and provided substantial data supporting, these points.
In December 2017, the Basel Committee on Banking Supervision (BCBS) issued its final Basel III framework in a document titled Basel III: finalizing post- crisis reform.
In January 2024, AWG produced a document updating its 2016 study – for use by regulators and banks in implementing, applying or interpreting, or considering reforms or modifications to, that Basel III framework.
In this document, AWG depicts the continuation (confirmed from 2016 – 2023) of low LGDs, and the unique features of, and data supporting LGDs for, aircraft-backed loans).
AWG submissions – capital requirements
In July 2026, AWG submitted a letter to the European Central Bank on Capital Requirements and CRD VI.
The letter addresses the overly conservative terms and application of CRR3 given the well-documented low risk in loans backed by modern aircraft equipment. The letter makes several specific proposals for consideration to address the adverse effects of such terms and application on the European bank finance and aviation sectors. AWG has, in its letter, requested consultations on these items. This letter is not of public record.
In April 2026, AWG submitted a letter to the European Commission on the competitiveness of the EU banking sector – with reference to capital requirements. It responded to a formal consultation, and, thus, the AWG letter is of public record. The letter can be found here.
AWG statements
In February 2026, AWG released a policy statement on withholding taxes in the aviation sector.