The EACB welcomes the opportunity to comment on the EBA’s draft Guidelines on the appropriate subsets of sectoral exposures to which competent or designated authorities may apply a systemic risk buffer (SyRB). In our response, we question whether the timing of this regulatory initiative is appropriate in the current context.
On the one hand, the effectiveness of other EBA initiatives, such as the review of the Guidelines on SREP, ESG risk management, or scenario analysis, is not yet known, particularly where the application date has recently started or will only start in 2027.
On the other hand, the draft Guidelines are being introduced at a moment when the broader European policy debate is focused on simplification, proportionality and competitiveness. In this context, it would have been preferable to reflect further on whether this initiative is aligned with those wider policy objectives. The European Commission is actively working to reduce regulatory complexity and strengthen the competitiveness of the EU financial sector, as also confirmed by the recent consultation on the competitiveness of the EU banking sector. Against that background, amendments to a macroprudential tool that introduce additional layers of sectoral granularity, particularly in relation to climate risk, appear difficult to reconcile with the overall initiative of the legislators.