Brussels: The body charged with managing the orderly failure of Europe’s largest banks is rewriting the rulebook on what keeps a collapsing lender alive long enough to be saved. On 12 June the Single Resolution Board opened a technical consultation on updated guidance covering liquidity and funding in resolution, the unglamorous plumbing that determines whether a rescued bank can actually open its doors the morning after.
The lesson driving the revision is recent and painful. The banking turmoil of 2023, which felled Credit Suisse and a clutch of American regional lenders, exposed how quickly a bank can die of thirst rather than insolvency. Modern deposit runs move at the speed of a smartphone, draining funds in hours rather than days, and a bank can be technically solvent yet unable to meet withdrawals. Capital, the buffer regulators spent the post-2008 decade building, is little help if the cash itself evaporates overnight.
The board’s response is to consolidate and sharpen its expectations into a single document, spelling out how banks should measure, forecast and prove their access to liquidity in the chaotic window after a resolution is triggered. That means identifying which assets can genuinely be turned into cash at speed, mapping where collateral sits across borders and legal entities, and demonstrating that funding will not freeze precisely when it is needed most. The guidance also clarifies how public backstop facilities might bridge the gap until private markets reopen.
The stakes are systemic. Resolution, as opposed to a taxpayer bailout, only works if a failing bank can be stabilised over a weekend and reopened without sparking panic elsewhere. If depositors and counterparties doubt that a resolved bank can pay, the run simply migrates to the next institution, and the careful architecture built since the last crisis unravels. Liquidity, in other words, is the hinge on which the entire resolution framework swings.
Not everyone welcomes tighter expectations. Banks argue that holding ever-larger pools of liquid assets in case of a hypothetical failure is expensive, that it ties up resources that could fund lending, and that overly prescriptive rules risk a one-size-fits-all approach to institutions with very different business models. Supervisors counter that the cost of underpreparation, measured in contagion and lost confidence, dwarfs the carrying cost of a prudent buffer.
Because this is a consultation rather than a final rule, the guidance will now be tested against industry feedback before the board settles its expectations. The direction, however, is unmistakable. After watching how fast a wired-up bank can hemorrhage deposits, Europe’s resolution authority wants its largest lenders to prove, in advance and in detail, that they can find cash when the alarm sounds, not merely that they are solvent on paper.




