EBF CONSULTATION RESPONSE
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EBF response to the EBA Public Consultation on the Revised Guidelines on SREP and supervisory stress testing

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BRUSSELS, 11 February 2026  – The European Banking Federation (EBF) welcomes the supervisory intent to streamline supervision and support risk-based supervision. While the draft revisions are a positive step forward, members believe that more should be done to re-focus streamlining efforts on risk rather than on processes, in alignment with international trends. Aligning supervisory expectations more closely with the materiality of risks, rather than the volume or granularity of documentation, would ensure that banks deploy resources in ways that most effectively support stability and resilience. The key messages on the consultation response are:

• At a time when the EU is focused on simplification, the Guidelines have not gone sufficiently far in the simplification effort. Repetition in the draft SREP Guidelines of requirements that are embedded in a large number of other guidelines both complicates compliance efforts and raises the risk of emerging disconnects between the underlying Guidelines and the elements repeated in the SREP guidelines.
• We believe that instead of resource-intensive, overly technical and uniform approaches, the Guidelines should put more emphasis on institution-specific, risk-based assessments that take into account the business model of the institution rather than strict benchmarking-based assessments with implied automaticity in terms of further steps and escalation. They should also address issues related to continuous supervision, such as reducing the operative burden related to the intense scrutiny on internal models and their up-to-datedness and scope, as well as the related portfolios.
• In addition, further transparency is needed on the general interaction between Pillar 1 Requirements (P1R) and P2R and how competent authorities determine P2R in the light of output floor and beyond. To ensure institutions have a clear understanding of SREP assessment and interaction between P1R and P2R, considering the output floor, the components of P2R have to be made transparent to institutions in SREP assessment. We suggest adding a mandatory communication requirement for the outcome of the Pillar 1 and P2R interaction assessment to institutions. This would foster transparency and allow institutions to understand the rationale behind any P2R adjustments.

For more information please contact:

Kalina Pateva, Policy Adviser – Prudential Policy and Supervision, k.pateva@ebf.eu

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

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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.