Lenders across the bloc have closed out their submissions to the European Commission’s first dedicated competitiveness consultation for the banking sector, with industry, supervisors and the European Central Bank converging — for once — on a shared diagnosis: the post-2008 rulebook now stops more lending than it stops crises, and the next legislative cycle must tilt back toward growth without surrendering financial stability. The targeted consultation closed on 19 April after eight weeks of submissions; the associated call for evidence had wrapped up a month earlier. A consolidated report from the financial services directorate-general is now expected in the third quarter.
The exercise launched on 11 February by Maria Luís Albuquerque, the commissioner for financial services and the Savings and Investments Union, was unusual in scope. It asked banks not only about prudential complexity, the perennial gripe, but also about the interaction of supervisory expectations across the European Banking Authority, the Single Supervisory Mechanism, national regulators and the European Securities and Markets Authority. The Commission also invited input on how banking-union completion, including the long-stalled European Deposit Insurance Scheme, should be sequenced against a competitiveness agenda inherited from the Draghi report.
The ECB’s response, published in mid-April, was striking in tone. The Eurosystem warned explicitly that ‘competitiveness stems from harmonisation, not deregulation’ — a sentence clearly aimed at banking trade associations that have spent the spring asking for prudential rollback. The supervisors did concede that there is room to simplify reporting, calibrate proportionality for small lenders, and rationalise the patchwork of national waivers within the Single Rulebook. But they drew a hard line against rolling back capital, liquidity or resolution requirements.
The consultation closed barely a day before the Official Journal carried the final text of the Crisis Management and Deposit Insurance reform package, the dossier that has dominated the post-2008 bank resolution debate. Regulation 2026/808 amends the Single Resolution Mechanism Regulation; Directive 2026/806 reshapes the Bank Recovery and Resolution Directive; and Directive 2026/804 updates the Deposit Guarantee Schemes Directive. The trilogue compromise reached in June 2025 stretched the resolution perimeter to a wider class of medium and smaller banks and authorised resolution authorities to draw on industry-funded safety nets — chiefly national deposit guarantee funds — as additional financing during a resolution. The political logic was to keep taxpayer money out of bank failures while preserving depositor access; the operational logic remains contested.
For mid-sized lenders, the CMDI package is a mixed gift. It clarifies that they will be resolved rather than wound up under national insolvency, which most prefer. But it also requires them to build up minimum requirements for own funds and eligible liabilities that smaller balance sheets struggle to issue cost-effectively. National banking associations in Germany, Italy and Spain have already begun pressing for delegated acts that smooth the transition.
The competitiveness consultation will feed into a Commission communication scheduled for the autumn, alongside the broader Savings and Investments Union work programme. That package is expected to include a fresh push on securitisation, a recalibration of the insurance prudential framework, and a follow-up to the Listing Act aimed at deepening capital markets. Whether the final text delivers a genuine competitiveness reset or another layer of administrative tinkering will depend on a balance the Commission has yet to strike: between Frankfurt’s insistence on prudential continuity and the industry’s argument that, on present settings, the next marginal euro of European savings will continue to find its way to American balance sheets.
