The patchwork approach to implementing the Basel III capital adequacy regime reveals that the effort to create a European banking union remains a work in progress, says Moody’s Investors Service in a report published Friday.

Moody’s research finds that various countries in the region have taken different approaches to implementing Basel III. For instance, the Netherlands and Sweden have set systemic risk buffers for their banks, the Moody’s report says, while other countries have not. The U.K. has said it intends to enforce a systemic risk buffer starting in 2019, the Mooyd’s report notes, whereas Italy has not applied any buffers.

“Implementation of the capital architecture, which is itself rather complex, is further complicated by the fact that different regulatory authorities are responsible for setting different buffers. This has led to a patchwork effect across Europe, both in the pace of decision-making and the size of the buffers set for each nation’s banks,” says Alain Laurin, an associate managing director at Moody’s, in a statement.

Additionally, there are significant differences between the common equity Tier 1 positions being reported by the banks in the region, the Moody’s report says, which may not reflect the differences in their riskiness.

The Moody’s report also notes that a planned single bank crisis management system and resolution framework for Europe is not yet in place. “Since taxpayer money may still be required in the case of bank failures, member states consider they should have a say in setting banks’ capital buffers, despite governments’ claim that they will no longer bail-out banks,” the report says.