Elevare Partners
Explainer on Additional Tier 1 (AT1) sukuk and Basel III bank capital in Saudi Arabia
2026-06-21· Rasha El Hassan· 3 min read

What Is an AT1 Sukuk?

An AT1 sukuk is a perpetual, Shariah-compliant instrument that banks issue to build going-concern regulatory capital under Basel III. It has no fixed maturity, its profit distributions can be cancelled, and it carries loss-absorption features that can write it down or convert it at the point of non-viability. This explainer sets out how it works and where it sits in the capital structure.

Why this matters in Saudi Arabia

Saudi banks have become regular issuers of Additional Tier 1 (AT1) sukuk, and for good reason: it is the instrument of choice for building bank capital in a Shariah-compliant market. Understanding what an AT1 sukuk is — and is not — matters for anyone reading bank disclosures, following the local debt market, or assessing a bank's capital position. This is a descriptive explainer, not investment advice.

What an AT1 sukuk is

An AT1 sukuk is a perpetual, Shariah-compliant instrument that a bank issues to build regulatory capital under the Basel III framework. Three features define it.

It is perpetual — there is no fixed maturity date. The bank may redeem it after a defined non-call period (often five or six years, described as PerpNC5 or PerpNC6), but it is not obliged to. Investors price it on the expectation of a call, not a maturity.

Its profit distributions can be cancelled. The bank can choose, or be required, to skip a distribution, and the skipped amount is typically non-cumulative — it does not accrue. This is a sharp difference from a conventional coupon.

It carries loss absorption. At the point of non-viability — the threshold at which the regulator determines the bank cannot continue without support — the instrument can be written down or converted, at the regulator's discretion. AT1 sukuk are commonly structured on a mudaraba basis to achieve this within a Shariah-compliant form.

Where it sits in the capital structure

Bank regulatory capital under Basel III has three layers. Common Equity Tier 1 (CET1) is the highest quality — ordinary shares and retained earnings, absorbing losses first. Additional Tier 1 (AT1) is the next layer: going-concern capital that absorbs losses while the bank is still operating, but does not meet every CET1 criterion. Tier 2 is gone-concern capital, absorbing losses only if the bank fails.

Only perpetual instruments qualify as AT1; Tier 2 instruments can have a maturity. In a bank's order of loss-bearing, an AT1 sukuk ranks below senior debt and depositors — it bears losses before they do — but above ordinary shares. That subordination is the trade-off for its profit distribution.

How it is regulated and issued

In Saudi Arabia, a bank's capital adequacy is supervised by the Saudi Central Bank, while listing and disclosure of the instrument run through the CMA and the Saudi Exchange. AT1 sukuk are frequently issued by private placement to qualified investors locally, or internationally under Regulation S, sometimes through a special-purpose vehicle. Saudi banks across the sector have issued them, and the format has become the standard route for GCC Islamic banks building Tier 1 capital.

The short version: an AT1 sukuk lets a bank strengthen its capital base without diluting shareholders — and the investor accepts perpetual tenor, cancellable distributions, and loss absorption in exchange for the return. That balance is the whole instrument.

Frequently asked questions

Is an AT1 sukuk debt or equity?

Neither cleanly. An AT1 sukuk is a hybrid instrument: it pays a profit distribution like debt but has equity-like features — it is perpetual, its distributions can be cancelled, and it can absorb losses by being written down or converted. Under Basel III it counts as going-concern regulatory capital, sitting above ordinary shares but below senior debt and depositors in the capital structure.

Why do banks issue AT1 sukuk?

To build Tier 1 regulatory capital efficiently. Basel III requires banks to hold defined levels of high-quality capital, and AT1 instruments let a bank strengthen that capital base without issuing new ordinary shares and diluting existing shareholders. For GCC Islamic banks, the sukuk format has become the preferred structure for this purpose.

What is the point of non-viability?

The point of non-viability is the threshold at which the regulator determines a bank is no longer viable without support. At that point, an AT1 sukuk's loss-absorption feature is triggered — the instrument can be written down or converted, at the regulator's discretion — so that it absorbs losses before public support is provided. It is the feature that makes AT1 count as going-concern capital.

Sources

How Elevare helps

Elevare Partners works with listed and IPO-bound companies in the Kingdom across the services relevant to this topic.

Rasha El Hassan
Written by
Rasha El Hassan
Head of Investor Relations, Governance & ESG

This content is for general information only and is not legal, financial or regulatory advice. Refer to the official CMA and Tadawul rules and qualified advisors before acting.

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