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Detailed Assessment of Observance – Basel Core Principles for Effective Banking Supervision in the Euro Area

Core Content

This report provides a detailed assessment of the euro area's compliance with the Basel Core Principles (BCP) for Effective Banking Supervision, conducted as part of the IMF Financial Sector Assessment Program (FSAP). The assessment highlights the progress made by the Single Supervisory Mechanism (SSM), led by the European Central Bank (ECB), in strengthening banking supervision since the last FSAP in 2018. It also identifies ongoing challenges and areas for improvement.

Main Findings

A. Summary of Key Findings

1. Supervisory Strengthening: The SSM has significantly improved the quality of supervision of Significant Institutions (SIs) since its establishment in 2014. It has a clear mandate, independence, and a robust supervisory framework.

2. Legal and Operational Challenges: The SSM faces resource constraints, especially in areas like ICT risk and internal model approvals. The legal framework is complex and fragmented, with national laws not always harmonized, leading to potential regulatory arbitrage.

3. Basel III Implementation: The adoption of the Capital Requirements Regulation (CRR 3) and Capital Requirements Directive (CRD 6) is a major milestone, but some deviations from Basel standards remain. The FRTB implementation has been postponed, and certain issues identified in the 2018 assessment persist.

4. Risk-Based Supervision: The SSM has adopted a highly codified and standardized approach to supervision, which has led to a more consistent but less agile process. Efforts to improve risk-based supervision, such as the risk tolerance framework and simplification of SREP, are ongoing.

5. Climate Risk Integration: The ECB has been a leader in incorporating climate-related financial risks into its supervisory framework, with several binding decisions and continuous dialogues with institutions. However, traditional risk categories still require attention.

B. Detailed Findings

1. Responsibility, Objectives, Powers, Independence, Accountability (CPs 1-2)

• The ECB and national competent authorities (NCAs) share responsibility for banking supervision across 21 euro area member states.
• The SSM operates under a well-established legal framework, including EU Regulations and Directives.
• The ECB has the power to authorize and supervise SIs and LSIs, but faces challenges in harmonizing national laws and maintaining consistent enforcement across member states.

2. Ownership, Licensing, and Structure (CPs 4-7)

• The legal framework supports the SSM in ensuring the sound licensing of new credit institutions.
• Licensing criteria vary across national laws, increasing complexity for the ECB.
• CRD 6 introduces new powers for competent authorities to assess material holdings, but the ECB's ability to intervene in cross-border ownership changes is limited.

3. Methods of Ongoing Supervision (CPs 8-10)

• The SSM uses the Supervisory Review and Evaluation Process (SREP) as a core tool for ongoing supervision.
• The SREP is a forward-looking, holistic assessment of a bank's viability, but its scores are sticky and lack differentiation among institutions.
• The SSM has taken steps to improve transparency and communication with banks, but more work is needed to streamline processes and ensure supervisory convergence.

4. Supervisory Outputs and Challenges

• The comprehensive and codified approach leads to a high volume of findings, which can be burdensome to follow up on.
• The ECB has implemented initiatives to better monitor findings and measures, but reducing the stock of open measures requires clearer expectations in SREP letters.
• The Early Warning System is effective but may not be suitable for systemic crises involving multiple institutions.

5. Oversight of Less Significant Institutions (LSI)

• The ECB has made progress in supervising LSIs through moral suasion and benchmarking.
• However, there are still inconsistencies in the use of SREP and Pillar 2 requirements among NCAs.
• Further work is needed to improve supervisory convergence and strengthen the oversight of FMI classified as LSIs.

Key Recommendations

• Delegation of Decision-Making: Further delegation of decision-making to lower levels could improve efficiency.
• Governance of Budgetary Processes: The budgetary process should involve early consultation with supervision lines to better align resources with workload.
• Reduction of Regulatory Fragmentation: Efforts should continue to harmonize national laws and reduce differences in supervisory approaches.
• Streamlining Supervisory Processes: Simplifying SREP planning and focusing on risk-based approaches can enhance agility and impact.
• Improving Supervisory Convergence: Harmonizing priorities and methodologies across member states is essential for consistent and effective supervision.
• Enhancing Data Quality: Greater standardization and flexibility in supervisory reporting can improve data quality and reduce administrative burden.

Conclusion

The SSM has made significant strides in enhancing banking supervision in the euro area, but challenges remain in terms of legal complexity, resource allocation, and supervisory convergence. Continued efforts to align with international standards and improve the efficiency and impact of supervision are necessary for the SSM to maintain its effectiveness in ensuring financial stability and safety.