“The reasons in favour of an EDIS … have become particularly important now. We need tools to enhance confidence in the banking system, preserve financial stability and avoid exacerbating the bank-sovereign doom loop.”

EBF banking union webpage - ECB Luis_de_Guindos

“We should not repeat past mistakes of leaving the house half-built and, thus, finalise the Banking Union by erecting and completing its third pillar”

“We will only come out of this crisis stronger if we act together as Europeans. This means first and foremost strengthening and completing the Banking Union.”

EBF banking union webpage - Enria_portrait

EBF believes that creating the Banking Union has been one of the major achievements following the financial and economic crisis. Today the Banking Union consists of two pillars: a Single Supervisory Mechanism (SSM) and a Single Resolution Mechanism (SRM). Both are contributing to financial stability and a level-playing field for banks in the Eurozone. Centralised supervision has re-shaped and harmonised how the Eurozone’s significant banking institutions are supervised and has further aligned the application of the EU’s Single Rulebook. Centralised resolution planning and preparedness – as well as a dedicated Eurozone level resolution fund – provide confidence that a crisis in a significant bank can be managed efficiently and without cost to taxpayers.

There is also ambition to further break the bank–sovereign doom loop by building a European Deposit Insurance System as the Banking Union’s third pillar. This is taking longer than initially expected since a first legislative attempt to create an EDIS in 2015 did not find sufficiently broad support. Moreover, some underlying divergences between the Members States need to be ironed out for the integration of the Eurozone’s banking sector to progress.

Based on experience gained over the last years, European policymakers and banks are now reviewing the structures in place which might require some corrections and additional building blocks.


EBF welcomes that the Commission has made the completion of the Banking Union a priority. DG FISMA is currently preparing a set of legislative proposals to be presented by end-2021. Issues on the table include:

  • Early Intervention Measures and their place within the regulatory framework
  • An enhancement of the Bank Recovery and Resolution Directive (BRRD) to provide also for more harmonised resolution/liquidation of mid-sized banks
  • Amendments to the BRRD to adjust the creditor hierarchy in the event of a resolution-related bail-in
  • Facilitating sector integration by bridging the different national concerns related to cross-border banking groups
  • Further harmonisation for national deposit guarantees schemes (DGS-D) legislation
  • The Banking Union’s third pillar reflecting developments since the 2015 EDIS proposal

EBF and its members are convinced that completing the Banking Union is of great importance. Together we are in a unique position to span the banking sector perspectives across the Eurozone. We are working closely together in a dedicated Banking Union group to shape and provide our views to policy makers and stakeholders.


EBF feedback to DG Fisma’s Crisis Management & Deposit Insurance (CMDI) framework consultation – Full position

EBF feedback to DG Fisma’s Crisis Management & Deposit Insurance (CMDI) framework consultation – Summary

EBF feedback on FISMA Banking Union Roadmap