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Ursula Vogel

5 August 2025
MACROPRUDENTIAL BULLETIN - ARTICLE - No. 30
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Abstract
Unwarranted heterogeneity in O-SII buffer levels across the European banking union may have adverse consequences for financial stability and the level playing field in the banking market. Analysis of national buffer-setting yields evidence of heterogeneity which does not result from differences in the size, concentration and funding structure of the domestic banking systems. From a banking union perspective, buffer-setting by national authorities results in heterogeneity at both the upper and the lower end of the distribution of a bank’s systemic relevance. The recent enhancement of the ECB’s O-SII floor methodology is designed to mitigate unwarranted O-SII buffer heterogeneity at the lower end of the buffer range. As the ECB can impose higher macroprudential requirements but not reduce macroprudential requirements, it is not possible for its methodology to address instances of unwarranted heterogeneity at the upper end.
JEL Code
G21 : Financial Economics→Financial Institutions and Services→Banks, Depository Institutions, Micro Finance Institutions, Mortgages
G28 : Financial Economics→Financial Institutions and Services→Government Policy and Regulation
5 August 2025
MACROPRUDENTIAL BULLETIN - ARTICLE - No. 30
Details
Abstract
Capital buffers for other systemically important institutions (O-SIIs) are set by national authorities. They vary greatly across the EU Member States participating in the banking union. On 1 January 2025 the ECB started using an enhanced floor methodology to assess national O-SII buffer decisions. This methodology adopts a banking union (BU) perspective to address “too-big-to-fail”-related risks at the BU level. The aim is to reduce the heterogeneity in O-SII buffers and achieve a more consistent treatment of the most systemically important institutions. Furthermore, the enhanced methodology recognises the progress made on the European banking union, in line with the approach taken in the G-SIB framework. It introduces a BU floor for O-SII buffers, calibrated based on a linear function mapping O-SII scores from the BU perspective to minimum buffer rates. The enhanced methodology will be fully phased in by 2028.
JEL Code
G21 : Financial Economics→Financial Institutions and Services→Banks, Depository Institutions, Micro Finance Institutions, Mortgages
G28 : Financial Economics→Financial Institutions and Services→Government Policy and Regulation