ECB Supervisory Reporting: The Cuts Buch Confirmed at Bruegel

ByRegReportingDesk

On 2 September 2026, ECB Supervisory Board Chair Claudia Buch used a Bruegel Annual Meetings panel in Brussels to put numbers on the supervisory reform that has been building through the year. For teams inside ECB-supervised banks, three of those numbers land directly on the reporting function: the ECB has agreed to cut the supervisory reporting it collects for its assessment of individual banks by around 20%, to halve the data points banks submit for the next EU-wide stress test, and to discontinue around 40 of its more than 100 supervisory guidance documents. ECB supervisory reporting, in short, is getting leaner.

Buch’s contribution, titled “Bank resilience and sustainable growth: two sides of the same coin”, tied the reform to the European Commission’s 17 July 2026 Communication on the competitiveness of the EU banking sector (COM(2026) 615 final). The framing matters: simplification is presented as a way to redirect effort toward material risks, not as a loosening of prudential standards.

That tension runs through the contribution. The reporting burden is coming down, while the leverage ratio, the output floor and faithful implementation of the Basel standards stay in place.

Related reading: our guide to the ECB SREP 2026 priorities.

The three ECB supervisory reporting numbers Buch confirmed

The concrete figures are worth pinning down first:

  • Around 20% less supervisory reporting collected as part of the ECB’s assessment of individual banks.
  • Half the data points for the next EU-wide stress test, which the ECB runs jointly with the European Banking Authority. That exercise runs every other year, and the 2025 round was the most recent, which places the next one in 2027.
  • Around 40 of more than 100 supervisory guidance documents discontinued because they are no longer relevant.

The measures have different scopes. The ECB’s roughly 20% reduction concerns supervisory reporting used in its assessment of individual banks. The halving of data points concerns the next EBA-coordinated EU-wide stress test, whose participating sample is narrower than the full population of directly supervised significant institutions. They sit alongside a larger EU-level EBA simplification consultation. The April 2026 package proposes a 16% reduction in data points in regular EU harmonised supervisory reporting, around a 55% reduction in EU-wide stress-test data requirements and up to a 65% reduction in supervisory benchmarking reporting, producing an overall net reduction of around 50% across the combined EBA reporting framework. The FINREP and COREP amendments are planned for a first reference date in September 2027; integration of stress-test starting-point data into regular reporting is proposed for the 2029 EU-wide stress test onwards, while the 2027 stress-test templates are intended to mimic the proposed FINREP, COREP and ESG changes. Our explainer on the EBA supervisory reporting simplification package sets out the consultation deadlines and templates in scope.

Keeping the two tracks separate avoids a common trap. Buch’s contribution is a supervisory statement, not an amendment to the legal reporting templates. The EBA’s main simplification ITS package remains a draft following the consultation that closed on 10 July 2026, so its proposed COREP and FINREP changes are not yet binding. My working assumption is that the ECB’s own 20% cut to bank-specific requests shows up first, ahead of the harmonised ITS change, so teams should plan for two reduction tracks on different clocks.

Pillar 2 in 2026: a new methodology built around double counting

Alongside the reporting cuts, the ECB is applying a new methodology this year for setting microprudential (Pillar 2) capital requirements, which Buch described as more predictable and transparent. The purpose has not changed: Pillar 2 captures risks not, or not sufficiently, covered by minimum requirements. What the methodology adds is a sharper focus on overlaps, so a risk already covered under Pillar 1 is not counted again. Pillar 2 guidance continues to address a bank’s specific exposure to future macro-financial risks.

This connects to a change with a hard date. The EBA’s revised Guidelines on SREP and supervisory stress testing, finalised on 26 June 2026, apply from 1 January 2027. The EBA states that they fulfil the Article 104a(7) CRD mandate to operationalise the requirements for institutions that become bound by the output floor. Separately, the EBA’s January 2025 Opinion provides for a temporary P2R cap when an institution first becomes bound by the output floor, subject to the conditions set out in that Opinion. Our note on the revised SREP Guidelines and Pillar 2 capital covers the ICAAP and ILAAP implications.

The new Pillar 2 methodology targets overlap removal, not capital relief. The ECB states that the new methodology is intended to avoid double counting while preserving its ability to capture risks not covered by minimum requirements and to exercise supervisory judgement; it does not state that an individual bank’s P2R will necessarily be lower. Any individual bank’s outcome still depends on its own risk profile.

Around 40 guidance documents retire, and “non-binding” does real work

The review of supervisory guidance is the most concrete simplification measure in the contribution. Out of more than 100 guidance documents, around 40 will be discontinued. Buch also restated a principle that tends to be overlooked: ECB supervisory guidance communicates expectations and good practices, it is non-binding, and it does not create legal obligations beyond those already set in EU and national law.

That restatement is an invitation to check your own documentation. Where a bank has hard-wired an ECB guide into a policy as though it were a rule, the retirement of that guide is a prompt to confirm the actual legal obligation and where it sits in the CRR, the CRD or national law. Our coverage of the ECB guidance discontinuation exercise tracks which publications are affected.

Several process changes travel with the guidance review. Straightforward capital transactions can now go through a fast-track procedure completed in about a week. Fit-and-proper re-assessments no longer require documents to be resubmitted where there have been no material changes. For internal models, banks can opt for an early implementation approach for material model changes, subject to prudential safeguards, and on-site investigations are becoming more targeted with shorter average missions.

What the reform leaves untouched

Buch drew a firm line under the resilience side, and it is the line reporting teams should carry into any conversation that treats simplification as capital relief. Prudential standards and rigour remain unchanged. The leverage ratio and the output floor stay in place as safeguards against underestimating risk, and the internationally agreed Basel standards are to be implemented faithfully, in a strictly risk and evidence-based way.

She was direct about the reasoning. Mistaking weaker capital requirements for a growth strategy was one of the two pitfalls she flagged. Banks directly supervised by the ECB hold a Common Equity Tier 1 ratio of around 16%, well above minimum requirements; shareholder distributions through dividends and buybacks have risen in recent years; and bank capital is not currently a binding constraint on credit supply. Buch argued that weaker standards could lead to higher shareholder payouts rather than to more lending.

The banking union backdrop: why cross-border still costs

The reporting and capital measures sit inside a larger argument about market integration. Because the Single Rulebook already harmonises banking regulation, Buch located the remaining barriers in national differences: insolvency regimes, consumer protection rules and mortgage market regulation. Deposit protection is still fragmented, and less than 2% of household deposits are held across borders (1.8% in July 2026). A European deposit insurance scheme would give savers the same protection across the union and weaken the bank-sovereign nexus.

The simplification thread reaches the capital stack too. The ECB’s High-Level Task Force on Simplification, whose report the Governing Council endorsed on 11 December 2025, recommended consolidating the several macroprudential capital buffers and harmonising the methods used to set them, for example by merging today’s buffers into a non-releasable and a releasable buffer. Our explainer on macroprudential buffer stacking covers how the current buffers are calibrated. Whether any of this becomes binding depends on the legislative banking package the Commission is expected to bring forward in the first quarter of 2027, following COM(2026) 615 final.

Frequently Asked Questions

Does the 20% reporting cut change my COREP and FINREP submissions now?

No. The 20% figure concerns the supervisory reporting the ECB collects for individual-bank assessment. The EU harmonised templates, including COREP and FINREP, change through the EBA’s Implementing Technical Standards, consulted on in April 2026 and proposed to apply from September 2027.

Do these reductions apply to less significant institutions?

The ECB directly supervises significant institutions, while less significant institutions are supervised by national competent authorities within the SSM. Buch said the 2026 focus is on increasing proportionality by linking supervision and reporting for small and non-complex institutions more closely to their risk profiles, so the direction of travel reaches smaller banks too.

Will the new Pillar 2 methodology lower my P2R?

Not automatically. The methodology targets overlaps where Pillar 1 already covers a risk, including once the output floor binds, so it can remove double counting. It preserves the ECB’s ability to add capital for risks minimum requirements miss, and supervisory judgement, so any outcome depends on the bank’s risk profile.

Once an ECB guide is discontinued, can we drop it from our internal policies?

The ECB states its guidance is non-binding and creates no obligations beyond EU and national law, so a discontinued guide no longer reflects a current supervisory expectation. The underlying obligations in the CRR, the CRD and national law remain, so the safer step is to re-anchor any policy that cited the guide to the actual legal source.

Key Takeaways

  • The ECB will cut around 20% of the supervisory reporting it collects for individual-bank assessment; confirm with your joint supervisory team which bank-specific requests fall away.
  • Data points for the next EU-wide stress test, run with the EBA and due in 2027, will be halved; build the lighter template into 2027 stress-test planning.
  • A new 2026 Pillar 2 methodology targets double counting between Pillar 1 and Pillar 2; the EBA revised SREP Guidelines apply from 1 January 2027 and operationalise the output-floor P2R cap established by EBA Opinion EBA/Op/2025/01.
  • Around 40 of the ECB’s 100-plus supervisory guidance documents will be discontinued; identify which discontinued guides your internal policies still rely on.
  • The leverage ratio, the output floor and faithful Basel implementation stay in place; the reform reduces reporting and process burden, not capital rigour.

Sources and References

  • Claudia Buch, “Bank resilience and sustainable growth: two sides of the same coin”, contribution at the Bruegel Annual Meetings, Brussels, 2 September 2026: bankingsupervision.europa.eu
  • European Commission, Communication on the competitiveness of the banking sector and the Single Market in banking, COM(2026) 615 final, 17 July 2026: finance.ec.europa.eu
  • ECB, “Simplification of the European prudential regulatory, supervisory and reporting framework”, High-Level Task Force on Simplification report, 11 December 2025: ecb.europa.eu (PDF)
  • EBA, “The EBA consults on major simplification of supervisory reporting”, press release, 10 April 2026: eba.europa.eu
  • EBA, Consultation Paper on revisions to ITS on supervisory reporting, Module 4 on Stress testing (EBA/CP/202607 Module 4), 10 April 2026: eba.europa.eu (PDF)
  • EBA, Final Report on the revised SREP and supervisory stress testing Guidelines, 26 June 2026: eba.europa.eu (PDF)
  • EBA, Opinion on the interaction between the output floor and Pillar 2 requirements (EBA/Op/2025/01), 21 January 2025: eba.europa.eu
  • ECB Banking Supervision, 2025 stress test of euro area banks, August 2025: bankingsupervision.europa.eu (PDF)
  • ECB Banking Supervision, Supervisory Review and Evaluation Process (SREP) and Pillar 2 requirement: bankingsupervision.europa.eu
  • Claudia Buch, “Making European banks fit for the future: promoting competition, safeguarding resilience”, The Supervision Blog, ECB Banking Supervision, 28 April 2026: bankingsupervision.europa.eu

What reporting teams should line up before 2027

The near-term actions are practical. Map which ECB bank-specific data requests your joint supervisory team expects to drop under the 20% cut, and separately track finalisation of the EBA’s draft ITS, including the proposed September 2027 first reference date, so any harmonised template changes are reflected in implementation planning. Re-anchor any internal policy that leans on a soon-to-be-discontinued ECB guide to its actual legal source, and read the new Pillar 2 methodology against your own output-floor timeline. The next fixed marker is the Commission’s banking package, expected in the first quarter of 2027.

Disclaimer: The information on RegReportingDesk.com is for educational and informational purposes only. It does not constitute legal, regulatory, tax, or compliance advice. Always consult your compliance officer, legal counsel, or the relevant supervisory authority for guidance specific to your institution.

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