Publications

Banking Stakeholder Group (BSG) feedback on EBA’s draft revised Guidelines for the Supervisory Review and Evaluation Process (SREP) and stress testing under Directive 2013/36/EU, addressing proportionality, ESG risk integration, operational efficiency, and supervisory transparency to enhance consistency and resilience in EU banking supervision.

European Banking Authority (EBA) analysis on access to banking services in the EU – examines challenges from digitalisation, branch closures, and regulatory disparities, reviews hard and soft law frameworks (DORA, CER Directive, Cyber Resilience Act), and proposes recommendations to ensure equitable financial inclusion for vulnerable groups across Member States.

Banking Stakeholder Group (BSG) responds to EBA’s consultation on revised internal governance guidelines under CRD VI, addressing proportionality, diversity, and alignment with DORA and national frameworks while highlighting concerns over prescriptive requirements and compliance costs.

Banking Stakeholder Group response to EBA consultation on amending Guidelines on the definition of default under CRR (EU) No 575/2013, addressing quantitative default triggers, forbearance measures, and risk-sensitive classification while balancing financial stability and debt restructuring under Article 178.

Banking Stakeholder Group’s response to EBA’s consultation on amending product oversight and governance guidelines for retail banking products, addressing ESG features and greenwashing risks to align with updated EU regulations and consumer protection standards.

EBA Banking Stakeholder Group response to draft Implementing Technical Standards amending Pillar 3 disclosures on ESG risks, equity exposures, and shadow banking entities under CRR 3, addressing proportionality, alignment with Taxonomy Regulation, and transitional provisions for enhanced transparency and reduced reporting costs.

EBA Banking Stakeholder Group response to draft Regulatory Technical Standards on AML/CFT risk assessment for obliged entities under AMLD, critiquing automated scoring, NPO and crowdfunding indicators, and advocating a principles-based approach over rules-based mandates.

EBA Banking Stakeholder Group’s feedback on draft Regulatory Technical Standards for calculating and aggregating crypto exposure values under CRR, addressing alignment with Basel standards, transitional rules, market risk approaches, and proportionality to support EU competitiveness and financial stability.

EBA Banking Stakeholder Group response to draft Regulatory Technical Standards on assessing materiality of changes to Internal Ratings Based (IRB) Approach under CRR, proposing simplifications, clarifying scope exclusions, and advocating for greater supervisory flexibility to streamline model approval processes.

EBA Banking Stakeholder Group response to draft Guidelines on proportionate retail diversification methods under CRR3 (Regulation EU 575/2013), addressing concerns on capital requirements impact, proportionality for smaller banks, and methodological choices for retail portfolio eligibility under the standardised credit risk approach.

EBA Banking Stakeholder Group response to consultation on draft Regulatory Technical Standards amending criteria for appointing central contact points (CCPs) for electronic money issuers, payment service providers, and crypto asset service providers under 4MLD, addressing thresholds, risk-based approaches, and CCP functions.

Banking Stakeholder Group (BSG) response to EBA’s draft Implementing Technical Standards on IT solutions for Pillar 3 Data Hub (P3DH), addressing disclosure formats, submission deadlines, taxonomy alignment, and resubmission policies under CRR3 to enhance transparency and comparability for large EU institutions.

EBA Banking Stakeholder Group (BSG) fifth end-of-term report (2020–2024) summarizing advisory contributions, technical working group activities, and recommendations on EU banking regulation, financial stability, and stakeholder engagement to support the Single Rulebook and EBA objectives.

Banking Stakeholder Group (BSG) response to EBA’s consultation on draft Regulatory Technical Standards (RTS) for prudent valuation under CRR, addressing implementation issues, fallback approaches, and capital impact assessments while balancing risk-based valuation and regulatory consistency.

Banking Stakeholder Group (BSG) response to EBA’s consultation on draft Guidelines for ESG risk management, supporting integration of ESG risks into risk frameworks while highlighting data challenges, alignment needs with ECB and CRD/IFR mandates, and advocating a phased approach for climate and broader environmental risks.

Banking Stakeholder Group (BSG) response to EBA’s discussion paper on Pillar 3 Data Hub (P3DH) processes, addressing challenges in data submission, IT implementation, timelines, resubmission policies, and alignment with CRR3 reforms for EEA financial institutions.

Joint Stakeholder Groups respond to EBA’s DORA consultation on Regulatory Technical Standards for ICT subcontracting, addressing proportionality, supply chain transparency, and risk assessment challenges for financial entities under Article 30(5) of Regulation (EU) 2022/2554.

Joint Stakeholder Groups respond to EBA, EIOPA, and ESMA consultation on DORA’s draft Regulatory and Implementing Technical Standards for major incident reporting, proposing harmonized timelines, proportionality for smaller entities, and alignment with NIS2 and PSD2 frameworks.

Joint Stakeholder Groups respond to EBA, EIOPA, and ESMA’s DORA consultation on draft Regulatory Technical Standards for threat-led penetration testing (TLPT), addressing scope, thresholds, purple teaming, and alignment with TIBER-EU while advocating for flexibility and proportionality in implementation.

Banking Stakeholder Group (BSG) responds to EBA’s consultation on Pillar 3 disclosure Implementing Technical Standards under CRR3, addressing output floor implementation, transitional arrangements, and market transparency while balancing EU-specific adjustments with Basel III alignment.

EBA consultation response from the Banking Stakeholder Group (BSG) supporting the extension of existing Joint Committee Guidelines on complaints handling to credit servicers under Directive (EU) 2021/2167, ensuring consistent borrower protections and supervisory efficiency in non-performing loan markets.

EBA Banking Stakeholder Group supports ISSB’s climate-related disclosure standards to enhance global transparency on climate risks, aligning with ESRS and SFDR frameworks to promote interoperability and reduce greenwashing in sustainable finance.

BSG response to Consultation on draft RTS on the requirements, templates and procedures for handling complaints under MiCAR

Joint Stakeholders Groups' response to Consultation on draft RTSs ICT risk management tools methods processes and policies

Joint Stakeholders Groups' response to Consultation on draft RTS on policy on the use of ICT services regarding CI functions

Joint Stakeholders Groups' response to Consultation on draft ITS on register of information

Joint Stakeholders Groups' response to Consultation on draft RTS on classification of ICT incidents

BSG response to Consultation on draft Guidelines amending the AML Risk-Based Supervision Guidelines to include crypto-asset service providers

BSG own initiative paper on DORA

BSG own-initiative report on BSG workshop on the finalisation of Basel III

BSG response to Consultation on draft Guidelines on resolvability testing

BSG response to EBA Consultation on amending Guidelines on ML/TF risk factors and on Guidelines on access to financial services

BSG response to ESAs Call for evidence on better understanding greenwashing

Banking Stakeholder Group (BSG) response to EBA’s discussion paper on integrating environmental risks into the EU prudential framework, supporting a risk-based approach, addressing measurement challenges, and emphasizing consistency with global standards and EU climate goals like the Taxonomy Regulation and Net Zero 2050.

BSG own-initiative paper on non-bank lending

BSG response to EBA Consultation Paper on Guidelines on Remote Customer Onboarding under Article 13(1) of Directive (EU) 2015/849 (EBA/CP/2021/40).

BSG own-initiative paper on “de-risking”

BSG own-initiative paper on “digitalisation: challenges for consumers”

BSG Response to EBA Consultation Paper on amending RTS on SCA and CSC under PSD2 (EBA/CP/2021/32)

BSG response to EBA Consultation Paper on the Guidelines on the role, tasks and responsibilities AML/CFT compliance officers (EBA/CP/2021/31)

BSG statement on Sustainable Finance for COP26

BSG Own-initiative paper on COVID-19 recovery and resilience

BSG Response to EBA Consultation Paper on the revised Guidelines on limited network exclusion under PSD2 (EBA/CP/2021/28)

BSG response to EBA Consultation Paper on Guidelines on common procedures and methodologies for the supervisory review and evaluation process (SREP) and supervisory stress testing under Directive 2013/36/EU (EBA/CP/2021/26)

BSG response to EBA Consultation Paper on the draft RTS on Individual Portfolio Management of loans offered by crowdfunding service providers under Art. 6(7) Regulation (EU) 2020/1503 (EBA/CP/2021/22)

BSG Response to EBA Consultation Paper on the revised Guidelines on recovery plan indicators under Article 9 of Directive 2014/59/EU (EBA/CP/2021/13)

BSG response to EBA Consultation Paper on Guidelines for institutions and resolution authorities on improving resolvability (EBA/CP/2021/12)

BSG response to EBA Consultation Paper on the Risk Based Supervision Guidelines (EBA/CP/2021/11)

BSG Response to EBA Discussion Paper on Integrated reporting (EBA/CP/2021/01)

BSG response to EBA Consultation Paper on GL on common assessment methodology for granting authorisation as credit institution (EBA/CP/2021/07)

BSG response to EBA Consultation Paper on the draft ITS on Pillar disclosures on ESG risk (EBA/CP/2021/06)

BSG response to ESAs consultation on Taxonomy–related product disclosures

BSG advice on AML

BSG response to Consultation on Guidelines on remuneration policies for investment firms

BSG response to EBA Discussion Paper on management and supervision of ESG risks (EBA/DP/2020/03)

BSG response to EBA Consultation Paper on Draft Guidelines on sound remuneration policies under Directive 2013/36/EU (EBA/CP/2020/24)

BSG response to EBA Consultation Paper on draft Regulatory Technical Standards (RTS) methodology to estimate P2 and CBR for setting MREL requirements

BSG response to EBA and ESMA consultation to revise joint guidelines for assessing the suitability of members of the management body and key function holders

BSG response to EBA Consultation Paper on technical standards on indirect subscription of MREL instruments within groups

BSG response to the EBA Consultation paper on draft Regulatory Technical Standards on impracticability of contractual recognition of bail-in

BSG response to the EBA “Discussion paper on the future changes to the EU-wide stress test

End of term of office report of the EBA's Banking Stakeholder Group