The document discusses the challenges and methodologies related to back-testing the expected shortfall (ES) in the context of evolving banking regulations, particularly following the Basel Committee's guidelines shifting from value-at-risk (VaR) to ES for market risk capital requirements. It highlights the advantages of ES over VaR but emphasizes the difficulties in its back-testing, which currently forces banks to use VaR for this purpose. The paper reviews existing and newly developed back-testing methodologies, noting their reliance on strong assumptions that can result in inconsistent outcomes.