Article 9(1) of Regulation (EU) No 1093/2010 requires the EBA to develop RRIs for the timely identification of potential consumer harm. For this purpose, the EBA is publishing a list of 11 RRIs that covers a wide variety of different types of products in the EBA’s remit (e.g. mortgage credit, consumer credit and payment accounts). The indicators aim to facilitate the monitoring of the banking markets across the EU/EEA by measuring the risk of consumer harm arising from the misconduct of the institutions, and from wider economic conditions.

They provide information that help the EBA and national competent authorities to prioritise their regulatory and supervisory work in the area of consumer protection but may be of interest to other, external stakeholders as well (Table 1)^[1].  The EBA published the RRIs for the first time in 2022 and updates them annually, which, over time, will allow the presentation of helpful time series and trends.

Table 1: EBA retail risk indicators

Source: EBA supervisory reporting data, payment fraud reporting data, World Bank

Mortgage credit and other consumer loans

For mortgage credit and consumer loans, the EBA’s RRIs capture the risks to consumers by measuring consumers’ ability to repay their loans ( see also Chapter 2.2 on banks’ asset quality). Overall, respective indicators point to improvements in consumers’ ability to repay loans, especially in Member States with the highest proportion of such loans. However, the data should be interpreted cautiously and seen in the wider context of the economic situation in a given Member State and the EU/EEA.

The share of loans with forbearance measures aims to also assess the access of consumers to forbearance measures. In general, a decrease in this ratio may indicate that consumers experience harm because their access to forbearance measures is lower over time. Though it may also be the case that the indicator decreases because of the overall strength of the economy and fewer customers requiring forbearance measures, or transitioning from a period in which higher levels of forbearance measures were needed to one in which fewer measures are necessary.

Between June 2023 and June 2024, the share of household loans with forbearance measures over total household loans decreased from 1.5% to 1.4% across the EU/EEA. The fall was significant in Member States with a comparatively high level of such loans –Greece, Cyprus, and Hungary, as well as Bulgaria, Poland, Croatia and Liechtenstein. The proportion of such loans increased significantly in Sweden, Luxembourg and Norway (Figure 79).

Source: EBA supervisory reporting data

The share of non-performing loans collateralised by residential immovable property aims to measure whether consumers face difficulties to make their mortgage payments. In general, a decrease in this ratio indicates that consumers’ financial situation is improving. However, it may also be the case that over time the indicator could for instance decrease if banks change their business model and/or limit providing mortgage products to certain consumers, and/or dispose of such loans.

Between June 2023 and June 2024, the share of NPLs collateralised by immovable properties over all such loans remained largely stable at 1.5% across the EU/EEA. Among the Member States where the ratio decreased, the most significant falls were observed in Member States with a high proportion of NPLs, such as Greece, Cyprus and Hungary, as well as Bulgaria and Malta. The only countries where the proportion of such loans increased noticeably were those with a very low proportion of NPLs last year, such as Sweden, Estonia, Norway, and Liechtenstein (Figure 80).

Source: EBA supervisory reporting data

The share of NPLs from credit for consumption increased slightly between June 2023 and June 2024, from 5.2% to 5.4%. The proportion of such NPLs decreased the most in Member States with high levels of NPLs, such as Greece, Hungary, and Cyprus, as well as Bulgaria and Malta, while increasing the most in Liechtenstein, Luxembourg, and Lithuania, albeit from among the lowest levels in the EU/EEA (Figure 81).

Source: EBA supervisory reporting data

Payment and deposit accounts

For payment and deposit accounts, the EBA’s RRIs capture the risks to consumers by measuring the profitability of holding deposits. The percentage of deposit interest expenses paid by banks to households over total household deposits measures the costs of holding deposits for banks, and in turn, the benefit to consumers. In general, a decrease in this ratio would mean that ceteris paribus holding deposits is less profitable for consumers. On the other hand, an increase would mean that ceteris paribus consumers are benefiting more from holding their deposits at a bank (see also Chapter 3 on the liability side of banks).

Between June 2023 and June 2024, the ratio increased from 1.0% to 1.6% indicating that deposits have become more profitable for consumers. The increase was noticeable in most Member States, and particularly so in Latvia, Estonia, Croatia, Bulgaria, Lithuania and Ireland, albeit from some of the lowest levels across the EU/EEA (Figure 82).

Source: EBA supervisory reporting data

Payment services

For payment services, some of the risks to consumers are captured by measuring the ratio of fraudulent payments in general and the losses borne by consumers as a result of fraud in particular^[2]. With regard to the former, the share of fraudulent card payments aims to measure the share of fraudulent transactions in the total volume and value of card payments. An increase in this ratio would indicate that consumers are more exposed to fraud in the context of their card payments.

In 2023, 0.015% of the volume of card payments in the EU/EEA were fraudulent – the same as in 2022. It ranged from 0.03% in France and Luxembourg to close to zero in Finland, Poland, Estonia and Latvia (Figure 83). The value of fraudulent card payments compared to the total value of card payments was 0.034% in the EU/EEA, up from 0.027% in 2022. In four Member States – Iceland, Luxembourg, France and Lithuania – the value of fraudulent payments exceeded 0.05%.

Source: EBA payment fraud reporting data

Another indicator is the share of fraudulent credit transfer transactions in the total volume of such payments. An increase in this ratio may indicate that consumers are more exposed to fraud in the context of their use of credit transfers.

In 2023, 0.002% of credit transfers in the EU/EEA were fraudulent – similar to the figure in 2022. The proportion ranged from 0.005% in the Netherlands, Lithuania and Malta to close to zero in Bulgaria, Iceland, Norway, Slovenia and Portugal (Figure 84). The value of fraudulent credit transfers as a proportion of the value of all such transfers was 0.0009% in the EU/EEA in 2023, compared to 0.0006% in 2022. Putting these two figures together, it becomes clear that in some Member States, while the volume is high, the value of such fraudulent transactions is low, while in others the value is significantly higher compared to the volume.

Source: EBA payment fraud reporting data

Furthermore, changes to the number of losses due to fraud that are borne by card payment services users are also monitored. From 2022 to 2023, the total value of losses from this type of payment dropped by 9% in the sample of 27 EEA countries for which EBA has data. This reduction was mainly driven by falls in Member States with the highest absolute levels of losses from this type of payment, such as France and the Netherlands (Figure 85).

Even though the total value of losses across the EU from this type of payment dropped by 9%, the total value of losses due to fraud borne by card payment services users increased in 17 of the 27 EEA countries between 2022 and 2023. The greatest percentage increase occurred in Estonia, Hungary and Denmark, while the greatest percentage reduction took place in Malta and the Netherlands. However, the quality of the data underlying this indicator requires further improvements to arrive at robust conclusions and, thus, results should be interpreted carefully.

Data shows an 11% increase during the past year in the value of losses due to fraud that are borne by the users of credit transfers. The results seem to be driven mainly by a significant increase in losses in large Member States, such as France, Spain and, to a lesser extent, Germany (Figure 86).

Between 2022 and 2023, the total value of losses due to fraud borne by users of credit transfers increased in 21 of the 28 EEA countries for which the EBA has data for both years. The greatest percentage increase occurred in Bulgaria, Romania and Hungary, while the greatest percentage reduction took place in Greece and Malta. However, akin to the caveat for Figure 85, the quality of the data underlying this indicator requires further improvements to arrive at robust conclusions and, thus, results should be interpreted carefully.

Access to financial services

Concerning access to financial services, the EBA RRIs include three indicators based on World Bank data – i) the percentage of people aged 15+ who have an account at a bank or another type of financial institution; ii) those who report having a debit or credit card; and iii) those who report borrowing any money from family, relatives or friends in the past year. As the Word Bank updates these indicators only every 3to 4 years, but the EBA publishes its RRIs on an annual basis, these RRIs remain unchanged for several years.

One indicator shows the percentage of people aged 15+ who report having an account at a bank or another type of financial institution or report personally using mobile money services in the past year. The higher the percentage, the higher the proportion of the adult population with access to the most basic financial service. The latest data available is for 2021 and shows that on average in the EU/EEA 96% of people had a bank account, with very close to 100% in more than half of EU/EEA states, and only Romania, Bulgaria and Hungary below 90%.

Another indicator is the percentage of people aged 15+ who report having a debit or a credit card. The higher the figure the higher the proportion of the adult population with access to such payment services. In 2021, on average 87% of people aged 15+ had a debit or credit card in EU/EEA Member States, with close to 100% in many states in the north of the EU/EEA, and figures below 70% in Romania and Croatia.

Finally, the percentage of people aged 15+ who report borrowing any money from family, relatives or friends in the past year is another RRI considered here. A higher percentage may indicate that fewer people have access to loans from financial institutions, and thus, resort to borrowing from family, relatives or friends. A high share may also indicate that the costs of borrowing have increased, making it less affordable to use financial services. In 2021, on average 15% of people have borrowed money from family, relatives or friends across the EU/EEA, with more than 25% in Bulgaria, Greece and Romania, and less than 10% in Portugal and Italy.

Abbreviations and acronyms