EBA Joint Decisions ITS: One Risk Report for P2R, P2G and Liquidity

On 25 September 2026 the European Banking Authority opened consultation EBA/CP/2026/19 on draft implementing technical standards that would repeal and replace Commission Implementing Regulation (EU) No 710/2014. That 2014 regulation sets the procedure, timetable and templates supervisors use to reach joint decisions under Article 113 of the Capital Requirements Directive (CRD) for cross-border banking groups. The EBA joint decisions ITS keeps the Article 113 machinery and rebuilds its paperwork around one integrated risk assessment report and, where the college can manage it, one joint decision document.

That document sets the group’s additional own funds requirement (P2R), its Pillar 2 Guidance (P2G) and any institution-specific liquidity requirement, at consolidated level and for each institution of the group at individual level. The draft brings P2G and the leverage-ratio add-ons (P2R-LR and P2G-LR) explicitly into the ITS: Directive (EU) 2019/878 (CRD V) added them to Article 113, and the EBA says the current ITS do not fully reflect them.

Related reading: EBA Revised SREP Guidelines: What EU Banks Must Review in ICAAP, ILAAP and Pillar 2 Capital

Key dates in the EBA joint decisions ITS consultation

• 25 September 2026: consultation paper and draft Annex published.
• 9 November 2026, 16:00 CEST: registration closes for the public hearing.
• 10 November 2026, 10:00 to 11:00 CEST: virtual public hearing.
• 1 January 2027: the EBA’s revised SREP Guidelines, which the draft is aligned with, start to apply.
• 4 January 2027, 23:59 CEST: comment deadline, as stated in the EBA press release.
• After finalisation: the EBA submits the draft ITS to the Commission for adoption and at the same time forwards it to the European Parliament and the Council for information. The Commission has three months, extendable by one, to decide whether to adopt it as an implementing regulation published in the Official Journal. Entry into force follows on the twentieth day, repealing Regulation 710/2014. No date is set yet.

Article 113 after CRD V: three decisions, one four-month clock

Article 113(1) CRD, as replaced by CRD V, lists three joint decisions: point (a) on own funds adequacy and the Article 104(1)(a) requirement, point (b) on liquidity findings under Article 86 and specific liquidity requirements under Article 105, and point (c) on the guidance on additional own funds under Article 104b(3). The draft calls them the capital requirements, liquidity and capital guidance joint decisions (draft Article 2(5) to (8)), applied at the level set under Article 110 CRD, whether individual, sub-consolidated or consolidated.

The draft binds supervisors: the consolidating supervisor and the relevant competent authorities of EU subsidiaries (draft Article 2(1)). It adds no template for a bank to file.

Older process notes can carry the wrong clock. The original 2013 text of Article 113(2)(b) gave colleges one month for the liquidity joint decision; CRD V set four months for all three. Under draft Article 7(3) to (5), each four-month period starts when the consolidating supervisor submits the parts of the Annex relevant to that decision, and draft Article 5(7) treats the report as complete only when it holds those parts. On that wording, the college meeting and the group’s own ICAAP submission are separate milestones from the start of the clock.

One report and one decision document, if the college can manage it

The draft replaces what the EBA describes as separate capital and liquidity risk assessment templates with a single integrated report in six parts. Draft Article 5(5) maps them: the capital requirements decision uses Parts I, II, III and V; the liquidity decision uses Parts I, II and VI; the capital guidance decision uses Parts I, II, IV and V. Decisions reached on the same date share one submission of Parts I, II and V (draft Article 5(6)).

Draft Article 3(5) says the consolidating supervisor “shall aim” to reach all three decisions on the same date and combine them in a single document. The impact assessment weighed making that mandatory (option 1a) and chose option 1b, which lets the consolidating supervisor split the decisions, for example where the stress test results informing P2G run on a different timeline. The single document is a target in the draft text.

What the Annex asks supervisors to fill in

Part I is an entity table with SREP categorisation, applicable waivers and total assets. Part II summarises SREP scores per risk (sub)category and lists other supervisory measures with deadlines. The EBA’s case for the redesign is partly that the current templates demand detail on every SREP risk category irrespective of materiality.

Parts III and IV hold the proposals: P2R, its risk components and P2R-LR in Part III; P2G and P2G-LR in Part IV. Each table shows the other measure as a memorandum row marked “not for decision”, so neither is decided twice. Values may be a ratio or an amount in the relevant currency, and draft Article 8(8)(a) allows conclusions that combine both.

Part V and Table 2 of Part VI are the rows a reporting team will recognise. Both are headed “Information from supervisory reporting” and carry Pillar 1 requirements, buffer components, own funds, TREA, the capital and leverage ratios, and the LCR and NSFR (see our guide to LCR, NSFR and ALMM liquidity reporting). The EBA says it removed template content obtainable from other sources, reporting included. I read this as resting more of the decision on the COREP, leverage and liquidity returns already filed for the chosen reference date, so a later resubmission for that date can move the figures the college works from. The draft is silent on how supervisors treat such resubmissions.

Qualitative measures, the output floor and macroprudential overlap

The EBA notes that colleges routinely decide measures on governance, risk management and controls, which the current ITS do not fully reflect. The draft writes them in: measures under Article 102 and Article 104(1), points (b) to (o), CRD are documented in Part II and summarised in the draft capital requirements joint decision (draft Article 8(4)(a)). One drafting point for respondents: the Annex heading for Part II Table 2 cites Article 104(1), points (b) to (l), while the consultation text and draft Articles 8 and 13 cite points (b) to (o).

The bigger change is a set of targeted questions. Part III asks which risks the P2R addresses that are not covered, or not sufficiently covered, by the Pillar 1 own funds requirements “(including the output floor)” or by the leverage ratio requirement in Article 92(1)(d) CRR, and how the proposal takes account of measures such as macroprudential buffers and CRR Article 458 measures. Part IV asks the same for P2G, with any P2R added to the list. Our note on the CRR3 output floor phase-in covers the Pillar 1 side. The EBA kept these systemic risk references (option 4a) despite differing national practice, and consultation question 4 asks whether the draft keeps add-ons away from risks the output floor or macroprudential measures already capture.

Calibration stays outside the draft. The ITS covers procedure, timelines and templates; the methodology for P2R and P2G sits in the SREP Guidelines, whose revised version applies from 1 January 2027 and repeals EBA/GL/2022/03. The Annex does draw on the group’s own processes: Parts III and VI ask for findings from the last ICAAP and ILAAP reviews, with a statement on whether the institution’s estimates are reliable enough to serve as an input.

What reaches the parent and the subsidiaries

The EBA weighed common templates for communicating joint decisions to firms (option 3a) and preferred the current approach (option 3b). The consolidating supervisor sends the joint decision document to the management body of the EU parent institution, and each relevant competent authority sends the parts that concern its local institutions to their management bodies (draft Article 10(1) and (2)). Format and wording stay with each supervisor.

Institutions also get two dates. Draft Article 3(4) requires supervisors to give them an indicative date for the consultation on the draft joint decision, a step that applies only where Member State law requires it, and an estimated date for communication of the decision.

Context comes from the EBA’s own college monitoring. Its Report on Supervisory Convergence 2025 found that some closely monitored colleges agreed aspects of joint decisions mainly in writing, with limited discussion of the quantitative capital and liquidity proposals in college meetings, and that documents were sometimes shared shortly before meetings (see our EBA supervisory convergence report 2025 note). The draft timetable names a dialogue on the draft group risk assessment report and its proposals (draft Article 6) and a second on the draft joint decision (draft Article 3(2)(g)).

Frequently Asked Questions

A host supervisor wants to change one subsidiary’s P2R mid-cycle. Does the whole college reopen the decision?

Not necessarily. Article 113(4) CRD allows an update in exceptional circumstances on a written, fully reasoned request, and the update may be handled bilaterally between the consolidating supervisor and the requesting authority. Under draft Article 16(2), the consolidating supervisor circulates the request with a draft joint decision document and sets a deadline for the other relevant competent authorities to ask for a wider process. If none does, the two authorities agree the update between them. The route is limited to institutions other than the EU parent institution or EU parent (mixed) financial holding company.

What if the college cannot agree within four months?

Article 113(3) CRD then moves the decisions to the individual authorities: the consolidating supervisor decides on a consolidated basis and each host authority decides for its subsidiaries on an individual or sub-consolidated basis. Draft Article 12 sets the deadline as the latest of three dates: one month after the four-month period expires, one month after any EBA advice following a consultation request, or one month after any EBA decision under Article 113(3) or another date the EBA sets.

Related Articles

• EBA Revised SREP Guidelines: What EU Banks Must Review in ICAAP, ILAAP and Pillar 2 Capital: the SREP methodology behind the numbers in a joint decision.
• EBA Supervisory Convergence Report 2025: What It Means for SREP and Prudential Reporting: the EBA’s review of SREP and college practice across the EU in 2025.
• ICAAP and ILAAP: the internal capital and liquidity adequacy processes whose review findings feed the risk assessment report.

Key Takeaways

• Planning assumption: capital requirements, capital guidance and liquidity decisions may arrive in one document or be split across different dates, for example where the stress test inputs to P2G follow a different timeline.
• Clock reference: all three decisions, liquidity included, run on four months from the consolidating supervisor’s submission of the relevant Annex parts.
• Data dependency: Part V and Part VI Table 2 take their figures from supervisory reporting as of a stated date, so a later resubmission for that date can change the figures the college worked from.

Sources and References

• EBA press release on the revised joint decisions ITS consultation (25 September 2026): EBA press release
• EBA consultation page for EBA/CP/2026/19: EBA consultation page
• EBA/CP/2026/19, Consultation Paper on draft ITS on the joint decision process under Article 113 of Directive 2013/36/EU (25 September 2026): EBA consultation paper (PDF)
• Annex to the draft ITS, Individual and group risk assessment report(s): EBA draft Annex (PDF)
• Directive 2013/36/EU (CRD), Articles 86, 102, 104, 104b, 105, 110 and 113: EUR-Lex
• Directive (EU) 2019/878 (CRD V), replacing Article 113 CRD: EUR-Lex
• Regulation (EU) No 575/2013 (CRR), Articles 92 and 458, with Article 92(1)(d) added by Regulation (EU) 2019/876 (CRR2): EUR-Lex; Regulation (EU) 2019/876
• Commission Implementing Regulation (EU) No 710/2014 of 23 June 2014 (current joint decisions ITS): EUR-Lex
• Regulation (EU) No 1093/2010 (EBA Regulation), Article 15 on ITS adoption, as amended by Regulation (EU) 2019/2175: EUR-Lex; Regulation (EU) 2019/2175
• EBA press release on the revised SREP Guidelines (26 June 2026): EBA press release
• EBA Report on Supervisory Convergence 2025, section 1.3 on supervisory colleges: EBA report (PDF)

Responding before the 4 January 2027 deadline

Of the six consultation questions, question 4 (overlap with the output floor and macroprudential measures) and question 6 (template design) bear most directly on a cross-border group, which has to decide whether to answer them and who owns the response. Registration for the 10 November 2026 hearing closes on 9 November at 16:00 CEST, and written comments go through the EBA consultation page by 4 January 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.