v3.26.1
Regulation and Capital Adequacy
3 Months Ended
Mar. 31, 2026
Regulation And Capital Adequacy [Abstract]  
Regulation and Capital Adequacy
Regulation and Capital Adequacy
The FRB is the primary regulator of Group Inc., a bank holding company (BHC) under the U.S. Bank Holding Company Act of 1956 and a financial holding company under amendments to this Act. The firm is subject to consolidated regulatory capital requirements which are calculated in accordance with the regulations of the FRB (Capital Framework).
The capital requirements are expressed as risk-based capital and leverage ratios that compare measures of regulatory capital to risk-weighted assets (RWAs), average assets and off-balance sheet exposures. Failure to comply with these capital requirements would result in restrictions being imposed by the firm’s regulators and could limit the firm’s ability to repurchase shares, pay dividends and make certain discretionary compensation payments. The firm’s capital levels are also subject to qualitative judgments by the regulators about components of capital, risk weightings and other factors. Furthermore, certain of the firm’s subsidiaries are subject to separate regulations and capital requirements.
Capital Framework
The regulations under the Capital Framework are largely based on the Basel Committee on Banking Supervision’s (Basel Committee) capital framework for strengthening international capital standards (Basel III) and also implement certain provisions of the U.S. Dodd-Frank Wall Street Reform and Consumer Protection Act. Under the Capital Framework, the firm is an “Advanced approaches” banking organization and has been designated as a global systemically important bank (G-SIB).
The Capital Framework includes the minimum risk-based capital and the capital conservation buffer requirements. The buffer must consist entirely of capital that qualifies as Common Equity Tier 1 (CET1) capital.
The firm calculates its CET1 capital, Tier 1 capital and Total capital ratios in accordance with both the Standardized and Advanced Capital Rules. Each of the ratios calculated under the Standardized and Advanced Capital Rules must meet its respective capital requirements.
Under the Capital Framework, the firm is also subject to leverage requirements which consist of a minimum Tier 1 leverage ratio and a minimum supplementary leverage ratio (SLR), as well as the SLR buffer.


Consolidated Regulatory Capital Requirements
Risk-Based Capital Ratios. The table below presents the minimum, capital conservation buffer and total risk-based capital requirements.
As of
MarchDecemberMarchDecember
2026202520262025
 StandardizedAdvanced
Risk-based capital minimum requirements
CET1 capital ratio
4.5%4.5%4.5%4.5%
Tier 1 capital ratio
6.0%6.0%6.0%6.0%
Total capital ratio
8.0%8.0%8.0%8.0%
Capital conservation buffer requirements
G-SIB surcharge (Method 2)
3.5%3.0%3.5%3.0%
Stress capital buffer
3.4%3.4%N/AN/A
Fixed buffer
N/AN/A2.5%2.5%
Countercyclical capital buffer
0.0%0.0%0.0%0.0%
Total
6.9%6.4%6.0%5.5%
Total risk-based capital requirements
CET1 capital ratio11.4%10.9%10.5%10.0%
Tier 1 capital ratio12.9%12.4%12.0%11.5%
Total capital ratio14.9%14.4%14.0%13.5%
In the table above:
The total risk-based capital requirements for each of the capital ratios consist of the required risk-based capital minimum and the capital conservation buffer requirements.
The G-SIB surcharge is calculated using two methodologies (Method 1 and Method 2), the higher of which is reflected in the firm’s capital conservation buffer requirements. Method 1 relies upon measures of the size, interconnectedness, substitutability, complexity and cross-jurisdictional activities of each G-SIB. Method 2 uses similar inputs but includes a measure of reliance on short-term wholesale funding instead of substitutability. As of both March 2026 and December 2025, the G-SIB surcharge (Method 2) was higher and therefore was reflected in the capital conservation buffer requirements.
Based on the firm’s 2025 Comprehensive Capital Analysis and Review submission, the FRB has set the stress capital buffer (SCB) for the firm at 3.4% starting October 1, 2025. In February 2026, the FRB announced that BHCs will continue to be subject to their current SCB requirements until they receive new SCB requirements in 2027. As a result, absent further action from the FRB, the 3.4% SCB will remain effective through September 30, 2027.


The table below presents information about risk-based capital ratios.
$ in millionsStandardizedAdvanced
As of March 2026  
CET1 capital$101,800 $101,800 
Tier 1 capital$115,189 $115,189 
Tier 2 capital$14,256 $11,683 
Total capital$129,445 $126,872 
RWAs$815,106 $763,768 
CET1 capital ratio12.5%13.3%
Tier 1 capital ratio14.1%15.1%
Total capital ratio15.9%16.6%
As of December 2025  
CET1 capital$104,297 $104,297 
Tier 1 capital$118,943 $118,943 
Tier 2 capital$11,722 $9,527 
Total capital$130,665 $128,470 
RWAs$727,338 $691,470 
CET1 capital ratio14.3%15.1%
Tier 1 capital ratio16.4%17.2%
Total capital ratio18.0%18.6%
In the table above, the Standardized risk-based capital ratios as of March 2026 decreased compared with December 2025, reflecting increases in both Credit and Market RWAs and a decrease in capital. The Advanced risk-based capital ratios as of March 2026 decreased compared with December 2025, reflecting increases in Credit, Market and Operational RWAs and a decrease in capital.
Leverage Ratios. The table below presents the leverage requirements.
As of
MarchDecember
 20262025
Tier 1 leverage ratio4.0%4.0%
SLR3.75%5.0%
In the table above, the SLR requirement is calculated as the sum of (i) a 3% minimum as of both March 2026 and December 2025 and (ii) a buffer of 0.75% as of March 2026 and 2% as of December 2025.
On January 1, 2026, the firm early adopted the modified Enhanced Supplementary Leverage Ratio (eSLR) standards, which replaced the 2% buffer applicable to G-SIBs, with a buffer equal to 50% of the firm's G-SIB surcharge (Method 1).






The table below presents information about leverage ratios.
For the Three Months
 
Ended or as of
MarchDecember
$ in millions20262025
Tier 1 capital$115,189 $118,943 
Average adjusted total assets$1,953,422 $1,810,007 
Total leverage exposure
$2,476,612 $2,297,597 
Tier 1 leverage ratio5.9%6.6%
SLR4.7%5.2%
In the table above:
Average adjusted total assets represents the average daily assets for the quarter adjusted for deductions from Tier 1 capital.
Total leverage exposure includes average adjusted total assets and the monthly average of off-balance sheet and other exposures, primarily consisting of derivatives, securities financing transactions, commitments and guarantees.
Tier 1 leverage ratio is calculated as Tier 1 capital divided by average adjusted total assets.
SLR is calculated as Tier 1 capital divided by total leverage exposure.
GS Bank USA
GS Bank USA is the firm’s primary U.S. bank subsidiary. GS Bank USA is a New York State-chartered bank and a member of the Federal Reserve System, is supervised and regulated by the FRB, the FDIC, the New York State Department of Financial Services (NYDFS) and the Consumer Financial Protection Bureau (CFPB), and is subject to regulatory capital requirements that are calculated under the Capital Framework. GS Bank USA is an “Advanced approaches” banking organization under the Capital Framework. The deposits of GS Bank USA are insured by the FDIC to the extent provided by law.

The Capital Framework includes the minimum risk-based capital and the capital conservation buffer requirements (consisting of a 2.5% buffer and the countercyclical capital buffer). The buffer must consist entirely of capital that qualifies as CET1 capital. In addition, the Capital Framework includes the leverage ratio requirement. GS Bank USA is required to calculate the CET1 capital, Tier 1 capital and Total capital ratios in accordance with both the Standardized and Advanced Capital Rules. The lower of each risk-based capital ratio under the Standardized and Advanced Capital Rules is the ratio against which GS Bank USA’s compliance with its risk-based capital requirements is assessed. In addition, under the regulatory framework for prompt corrective action applicable to GS Bank USA, in order to meet the quantitative requirements for a “well-capitalized” depository institution, GS Bank USA must also meet the “well-capitalized” requirements in the table below. GS Bank USA’s capital levels and prompt corrective action classification are also subject to qualitative judgments by the regulators about components of capital, risk weightings and other factors. Failure to comply with the capital requirements, including a breach of the buffers described below, would result in restrictions being imposed by the regulators.
The table below presents GS Bank USA’s risk-based capital, leverage and “well-capitalized” requirements.
As of
MarchDecemberMarchDecember
 2026202520262025
"Well-capitalized"
Requirements
Requirements
Risk-based capital requirements 
CET1 capital ratio7.0%7.0%6.5%6.5%
Tier 1 capital ratio8.5%8.5%8.0%8.0%
Total capital ratio10.5%10.5%10.0%10.0%
Leverage requirements 
Tier 1 leverage ratio4.0%4.0%5.0%5.0%
SLR3.75%3.0%N/A6.0%
In the table above:
The CET1 capital ratio requirement included a minimum of 4.5%, the Tier 1 capital ratio requirement included a minimum of 6.0% and the Total capital ratio requirement included a minimum of 8.0%. These requirements also included the capital conservation buffer requirements consisting of a 2.5% buffer and the countercyclical capital buffer, which the FRB has set to zero percent.

The SLR requirement is calculated as the sum of (i) a 3% minimum as of both March 2026 and December 2025 and (ii) a 0.75% buffer as of March 2026. On January 1, 2026, GS Bank USA early adopted the modified eSLR standards, which replaced the SLR requirement for insured depository institution subsidiaries of G-SIBs to be well-capitalized with a new buffer requirement equal to 50% of their parents’ G-SIB surcharge (Method 1), capped at 1%, in addition to the 3% SLR minimum.
The “well-capitalized” requirement was the binding requirement for the Tier 1 leverage ratio as of both March 2026 and December 2025 and the “well-capitalized” requirement was the binding requirement for the SLR as of December 2025.
The table below presents information about GS Bank USA’s risk-based capital ratios.
$ in millionsStandardizedAdvanced
As of March 2026  
CET1 capital$62,646 $62,646 
Tier 1 capital$62,646 $62,646 
Tier 2 capital$2,201 $617 
Total capital$64,847 $63,263 
RWAs$445,853 $345,372 
CET1 capital ratio14.1%18.1%
Tier 1 capital ratio14.1%18.1%
Total capital ratio14.5%18.3%
As of December 2025  
CET1 capital$64,071 $64,071 
Tier 1 capital$64,071 $64,071 
Tier 2 capital$2,052 $677 
Total capital$66,123 $64,748 
RWAs$409,796 $306,699 
CET1 capital ratio15.6%20.9%
Tier 1 capital ratio15.6%20.9%
Total capital ratio16.1%21.1%
In the table above:
The lower of the Standardized or Advanced ratio is the ratio against which GS Bank USA’s compliance with the capital requirements is assessed under the risk-based Capital Rules, and therefore, the Standardized ratios applied to GS Bank USA as of both March 2026 and December 2025.
The Standardized risk-based capital ratios as of March 2026 decreased compared with December 2025, reflecting increases in both Credit and Market RWAs and a decrease in capital. The Advanced risk-based capital ratios as of March 2026 decreased compared with December 2025, reflecting increases in Credit, Market and Operational RWAs and a decrease in capital.

The table below presents information about GS Bank USA’s leverage ratios.
For the Three Months
 
Ended or as of
MarchDecember
$ in millions20262025
Tier 1 capital$62,646 $64,071 
Average adjusted total assets$713,766 $656,463 
Total leverage exposure
$988,298 $912,004 
Tier 1 leverage ratio8.8%9.8%
SLR6.3%7.0%
In the table above:
Average adjusted total assets represents the average daily assets for the quarter adjusted for deductions from Tier 1 capital.
Total leverage exposure includes average adjusted total assets and the monthly average of off-balance sheet and other exposures, primarily consisting of derivatives, securities financing transactions, commitments and guarantees.
Tier 1 leverage ratio is calculated as Tier 1 capital divided by average adjusted total assets.
SLR is calculated as Tier 1 capital divided by total leverage exposure.
The FRB requires that GS Bank USA maintain cash reserves with the Federal Reserve. As of both March 2026 and December 2025, the reserve requirement ratio was zero percent. See Note 26 for further information about cash deposits held by the firm at the Federal Reserve.
GS Bank USA is a registered swap dealer with the CFTC and a registered security-based swap dealer with the SEC. As of both March 2026 and December 2025, GS Bank USA was subject to and in compliance with applicable capital requirements for swap dealers and security-based swap dealers.


Restrictions on Payments
Group Inc. may be limited in its ability to access capital held at certain subsidiaries as a result of regulatory, tax or other constraints. These limitations include provisions of applicable law and regulations and other regulatory restrictions that limit the ability of those subsidiaries to declare and pay dividends without prior regulatory approval. For example, the amount of dividends that may be paid by GS Bank USA are limited to the lesser of the amounts calculated under a recent earnings test and an undivided profits test.
In addition, subsidiaries not subject to separate regulatory capital requirements may hold capital to satisfy local tax and legal guidelines, rating agency requirements (for entities with assigned credit ratings) or internal policies, including policies concerning the minimum amount of capital a subsidiary should hold based on its underlying level of risk.
Group Inc.’s equity investment in subsidiaries was $145.52 billion as of March 2026 and $143.11 billion as of December 2025. The firm’s regulated subsidiaries were required to hold minimum equity capital of $116.21 billion as of March 2026 and $109.48 billion as of December 2025 to satisfy regulatory requirements.
Group Inc.’s capital invested in certain non-U.S. dollar functional currency subsidiaries is exposed to foreign exchange risk, substantially all of which is managed through a combination of non-U.S. dollar-denominated debt and derivatives. See Note 7 for information about the firm’s net investment hedges used to hedge this risk.