EBF Position Paper: Revised EBA Guidelines on limits on exposures to Shadow Banking Entities (SBE)

EBF POSITION PAPER

Revised EBA Guidelines on limits on exposures to Shadow Banking Entities (SBE)

Brussels, 10 July 2026 – The European Banking Federation (EBF) responded to the European Banking Authority (EBA) consultation on revised Guidelines on limits on exposures to Shadow Banking Entities (SBE).

The EBF welcomes the EBA’s revision of the Guidelines and, in particular, the simplification objective that the proposal mainly meets. Guidelines are now substantially shorter, they cut stand-alone definitions, they cross-reference the CRR and the Delegated Regulation specifying the criteria for identifying SBEs, and they move the capital basis from eligible capital to Tier 1 capital. These changes remove inconsistencies and make the framework clearer to apply, we therefore support the overall direction.

However, alongside these welcomed changes, the proposal contains elements that sit uneasily with the simplification objective and, in our view, work against it. Rather than easing the framework’s application, these changes would in substance widen its scope and add to institutions’ operational burden : a result at odds with the EBA’s simplification agenda.

Against this background, the EBF asks the EBA to take into account the following points that would advance the simplification objective:

Retain the 0.25% materiality threshold, preferably by inscribing it into EU law. As it’s removal is not mandated by level 1 or level 2 texts, and as it reduces the burden by allowing institutions to disregard immaterial exposures unlikely to pose significant risks, according to the EBA itself.
Preserve the fallback approach alongside the principal approach.
Introduce no binding individual or aggregate limits under Pillar 1.
Introduce an Official reference list for the application of the SBE criterion based on the Basel Core Principles (BCP).

These changes would allow the revision to meet the EBA’s ambition of making the Guidelines simpler and more coherent. On that basis, the EBF stands ready to engage constructively with the EBA as the Guidelines are being finalised.

Read the full response here

For more information please contact:

Gonzalo Gasos, Senior Director – Prudential Policy and Supervision, g.gasos@ebf.eu

Lucas Blanc, Policy Adviser – Prudential Policy and Supervision, l.blanc@ebf.eu

About the EBF:

The European Banking Federation is the voice of the European banking sector, bringing together national banking associations from across Europe. The EBF is committed to a thriving European economy that is underpinned by a stable, secure and inclusive financial ecosystem, and to a flourishing society where financing is available to fund the dreams of citizens, businesses and innovators everywhere.