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Banking rulebook gains crisis tools after recent liquidity stress

Luxembourg: The European banking framework has been reinforced through three converging tracks during the past eighteen months: the entry into application of the revised Capital Requirements Regulation in January 2025, the agreement on the Crisis Management and Deposit Insurance package, and the European Central Bank’s progressive operationalisation of the digital euro investigation. Together, the strands modernise the rulebook that emerged from the post-2008 reform cycle while addressing the structural changes wrought by digitalisation, climate risk and geopolitical fragmentation.

The Capital Requirements Regulation III and the Capital Requirements Directive VI implement the final elements of the Basel III framework. The new rules tighten the standards for measuring credit, market and operational risk, introduce the output floor that limits the divergence between internal-model and standardised approaches, and harmonise the treatment of environmental, social and governance risks across the EU. The output floor is phased in over five years, reaching 72.5 per cent by 2030. European banks have generally absorbed the impact within their existing capital buffers, but the heterogeneous effects across business models and across Member States have produced renewed debate about the cost of capital for European banks relative to US peers operating under different frameworks.

The Crisis Management and Deposit Insurance package, agreed in principle in late 2025, extends resolution tools to medium-sized banks that fall outside the current Single Resolution Mechanism scope. The reform clarifies the use of deposit guarantee scheme funds in resolution, opening a route to depositor protection that minimises taxpayer exposure. National deposit guarantee schemes will continue to operate alongside the proposed European Deposit Insurance Scheme, although the EDIS proposal remains stalled in the Council despite repeated calls from the ECB and the Commission for political agreement.

The Banking Union architecture has been reinforced through the Single Resolution Board’s expanding operational capacity and through the European Banking Authority’s role in technical standards. The most recent EBA stress test, published in 2025, demonstrated that European banks could absorb adverse scenarios involving prolonged recession, persistent inflation and renewed energy shocks, although the test exposed vulnerabilities concentrated in commercial real estate exposures and in cross-border banking groups with significant operations in emerging markets.

The digital euro project has advanced from preparatory phase to a multi-year development phase. The ECB’s Governing Council confirmed in October 2025 that it would proceed with the technical and operational preparations for a digital euro, with the Council preserving the option of an eventual issuance decision once the legislative framework is in place. The Commission’s legislative proposal for a digital euro and for euro cash, tabled in 2023, remains in trilogue negotiations. The proposed framework establishes the digital euro as legal tender alongside cash, with privacy guarantees, offline functionality and intermediated distribution through commercial banks and payment service providers.

The MiCA Regulation on crypto-asset markets, in full application since December 2024, has produced the first wave of authorisations for crypto-asset service providers and stablecoin issuers. The framework’s distinction between e-money tokens, asset-referenced tokens and other crypto-assets has been broadly accepted by industry. Enforcement has begun in cases of unauthorised offering and inadequate disclosure, with national competent authorities coordinating through ESMA. The MiCA framework’s interaction with the Anti-Money Laundering rulebook — including the new AML Authority operational since 2025 — has provided a comprehensive regime that several non-EU jurisdictions have referenced when designing their own crypto-asset frameworks.

ESG and sustainable finance disclosures have been reshaped by the simplification track. The Omnibus simplification packages, including the omnibus on sustainability reporting tabled in early 2025, scale back the scope and complexity of the Corporate Sustainability Reporting Directive and the Corporate Sustainability Due Diligence Directive. The compromise preserves the substantive sustainability transition agenda while reducing the administrative burden on smaller companies and aligning timelines with operational readiness. The European Sustainability Reporting Standards have been streamlined accordingly.

Geopolitical risk has been embedded in supervisory expectations. The ECB’s Supervisory Banking Statistics now publish disaggregated data on banks’ exposures to jurisdictions affected by sanctions and on the implementation of restrictive measures. Sanctions enforcement gaps identified in 2024 produced strengthened cooperation between supervisors and national sanctions authorities. The geopolitical risk-management chapter of the ECB’s banking supervisory expectations is now treated as comparable in importance to credit and operational risk frameworks, reflecting the structural integration of geopolitics into European financial supervision.