IMF-欧元区_发布金融部门评估计划文件_金融部门安全网技术说明_（英）-2025.7_44页_834kb

Banking Union Crisis Management and Financial Safety Nets: IMF Euro Area Assessment Summary

The IMF's Financial Sector Assessment Program (FSAP) 2025 report evaluates the Euro Area's financial safety nets, focusing on crisis management and bank resolution frameworks. The assessment highlights significant progress since the 2018 FSAP, including the establishment of the Single Supervisory Mechanism (SSM) and Single Resolution Board (SRB), improved loss-absorbing capacity in banks, and enhanced operational readiness. However, key gaps remain, necessitating reforms to create a more flexible and unified system.

Key Findings

• Achievements:

  • The Banking Union (BU) crisis management framework is operational, with the SSM and SRB working effectively. Banks have built substantial loss-absorbing capacity, with average MREL (Minimum Requirement for Own Funds and Eligible Liabilities) at 28% of risk-weighted assets.
  • The Single Resolution Fund (SRF) has reached its target size and is fully mutualized, backed by preliminary agreements with the European Stability Mechanism (ESM) for a backstop facility.
  • Courts and industry participants have largely accepted the BU legal framework, aiding crisis resolution.

• Challenges:

  • The resolution framework lacks flexibility to handle systemic crises, relying heavily on national insolvency options due to restrictive rules on SRF access and bail-in tools.
  • A comprehensive European deposit insurance system (EDIS) is missing, leading to fragmented funding and payout risks for depositors.
  • Liquidity provisions in resolution are inadequate, as demonstrated by high demands during bank failures, potentially overwhelming SRF and ESM resources.
  • Governance is complex, with the SRB's decision-making processes constrained by the European Commission (EC) and Council, increasing political interference.

Recommendations

• Financial Stability and Resolution Financing:

  • Introduce a financial stability exemption to SRF usage rules to enhance flexibility for systemic crises.
  • Strengthen the SRF and ESM backstop by allowing guarantees to central banks for liquidity support, with safeguards like EU fiscal backing.
  • Require national deposit guarantee schemes (DGSs) to contribute more upfront to resolution costs and increase funding targets.

• Recovery and Resolution Execution:

  • Improve contingency planning, including exercises for bridge banks and dry runs with potential acquirers.
  • Streamline bail-in execution by addressing cross-border legal issues and securities law challenges, particularly with the U.S. and U.K.
  • Increase flexibility in early intervention measures and align state aid rules with resolution frameworks.

• Deposit Insurance and Cross-Border Cooperation:

  • Establish a common EDIS to pool funding, reduce depositor risks, and improve resolution financing.
  • Enhance cross-border cooperation with third-country authorities through memoranda of understanding (MoUs) and resolution colleges, prioritizing security law harmonization.

• Governance and Decision-Making:

  • Strengthen SRB autonomy by advocating for treaty changes or reduced EC/Council involvement in resolution decisions.
  • Simplify decision-making processes and clarify accountability to ensure timely responses in crises.
  • Promote deeper harmonization of national laws to reduce discrepancies in creditor hierarchies and insolvency regimes.

Priority Timeline

• Immediate Actions (within 1 year): Address liquidity deficiencies, strengthen DGS backstops, and finalize SRF exemptions.
• Near-Term Actions (within 1-2 years): Introduce EDIS reforms, streamline governance, and complete state aid alignment.
• Medium-Term Actions (within 3-5 years): Implement administrative liquidation tools, enhance resolution college coordination, and achieve full EDIS mutualization.

The report underscores the need for swift reforms to ensure the BU is better equipped for future crises, emphasizing consistency across Member States and alignment with international standards.