LSI Stress Test 2026: Germany’s TSCR Plus 500bp Threshold for P2G
BaFin and the Deutsche Bundesbank presented the results of the LSI stress test 2026 on 24 September 2026, and the sentence with the longest reach sits in the last paragraph of the press release. Going forward, a less significant institution (LSI) receives Pillar 2 guidance (P2G, in German the Eigenmittelempfehlung) only if its capital ratios in the adverse scenario fall below its total SREP capital requirement (TSCR) plus a buffer of 500 basis points. The supervisors expect around 40% fewer institutions to receive an own funds recommendation as a result.
In total, 1,113 banks and savings banks took part, around 90% of German credit institutions and some 38% of aggregate total assets. In the adverse scenario their aggregate CET1 ratio falls by around 3.8 percentage points to 14.6%. Several dozen institutions would be at risk of no longer meeting their prudential capital requirements, fewer than in the 2024 exercise.
For reporting and capital planning teams, the change lives inside the return. The data collection workbook (Erhebungsbogen) submitted to the Bundesbank by 29 May 2026 displayed an indicative P2G computed from supervisory pre-filled TSCR figures, so the rows an institution confirmed or overwrote in May decide where its own threshold sits. The EBA SREP Guidelines that frame this national discretion, EBA/GL/2022/03, stay in force until EBA/GL/2026/06 replaces them on 1 January 2027.
Related reading: EBA Revised SREP Guidelines: What EU Banks Must Review in ICAAP, ILAAP and Pillar 2 Capital
The 2026 exercise in dates
- 27 March 2026: Bundesbank and BaFin issue the Ausfüllhinweise und methodische Vorgaben, the completion instructions and methodological requirements for the institution-wide information request.
- 30 March 2026: BaFin announces the exercise and the TSCR plus 500 basis point threshold.
- 1 April 2026: the stress test starts.
- 29 May 2026: submission deadline for the completed forms (Tz. 8), and the latest date for TSCR and TSLRR changes the form is designed to reflect (Tz. 61).
- 22 June 2026: last day to notify the supervisor of a one-time switch away from the general proportionality solution, with the resubmission due by 29 June 2026 (Tz. 41).
- 24 September 2026: results press conference in Frankfurt am Main.
- 1 January 2027: EBA/GL/2026/06 applies and repeals EBA/GL/2022/03.
The Q&A list on the Bundesbank’s LSI stress test page is dated 19 June 2026. Its header states that external FAQs will be published for the last time on 8 July 2026, and that they are to be taken into account in resubmissions during the data-quality process.
What the adjusted national P2G methodology changes
The results presentation compares the two methods on the 2026 data. Under the previous national method, roughly 50% of participating institutions would have received P2G. Under the new one, roughly 30% do. The slide expresses the same shift as two in five institutions that previously carried P2G now benefiting from the threshold.
That makes the headline 40% a relative reduction in the number of recipients. Roughly 70% of participants now fall outside P2G altogether, and the figure BaFin gave at the press conference is framed the same way: 40% of the institutions that would arithmetically have received a recommendation, but are very comfortably capitalised, will no longer be given one. Reading the 40% as a share of the whole LSI population overstates the effect by a wide margin.
The stated rationale is proportionality. According to the presentation and BaFin’s 30 March announcement, institutions with solid capital and/or low risks identified in the stress test should no longer receive a recommendation for additional own funds, and the supervisors describe an undershoot of the line as a risk-oriented early warning threshold. The same slide lists a third element next to the threshold itself: greater transparency through an indicative display of a possible P2G in the Erhebungsbogen.
The threshold has two parts. TSCR is the binding floor made up of the Pillar 1 own funds requirement and the Pillar 2 requirement (P2R) set in the SREP decision; the completion instructions describe the pre-filled figures as the institution-specific capital requirements under Pillar 1 and Pillar 2 (Tz. 61). The 500 basis points on top are a nationally set margin. None of the published documents explains how the 500 basis points were calibrated.
Two further gaps are worth keeping in view. The published wording compares “capital ratios” in the adverse scenario with the threshold, while the completion instructions define the stress result as the largest fall in the CET1 ratio over the three-year horizon against the 2025 starting value (Tz. 43). The ratio-by-ratio mechanics of the comparison sit inside the workbook and are not spelled out in the published text, and the sources do not say whether an equivalent margin applies to P2G for the leverage ratio (P2G-LR).
Where the 500 basis point line sits in EBA/GL/2022/03
The German legal chain is short. Section 6b(3) KWG allows BaFin to subject an institution to supervisory stress tests. Section 6d(1) KWG then requires the supervisor to determine the appropriate overall level of own funds for each institution on the basis of the SREP assessment under Section 6b(2) and the stress test under Section 6b(3), and to issue an Eigenmittelempfehlung equal to the gap between that level and the institution’s binding requirements. Section 6d mirrors Article 104b of the Capital Requirements Directive (CRD), inserted by Directive (EU) 2019/878, which requires competent authorities to communicate institution-specific guidance on additional own funds.
How supervisors use that power is shaped by the EBA SREP Guidelines. The version in force for the 2026 exercise is EBA/GL/2022/03 of 18 March 2022, and the completion instructions name it when they describe the TSCR figures pre-filled in the form (Tz. 61). Section 7.7.1 of those guidelines already holds the building blocks the German method relies on:
- Paragraph 424: P2G should protect against a potential breach of TSCR in the adverse scenario, and where the stress test outcome suggests no breach is expected, the competent authority may decide not to set P2G.
- Paragraph 426: for institutions outside SREP Category 1, supervisors may rely on simplified forms of supervisory stress tests when setting and updating P2G.
- Paragraph 428(b): P2G may be determined every second year, with a check in the intervening year on whether it is still relevant.
- Paragraph 430: P2G should cover at least the maximum stress impact, the difference between the lowest CET1 ratio in the adverse scenario and the actual CET1 ratio at the starting point.
- Paragraph 435: P2G is offset against the capital conservation buffer, against the countercyclical buffer only in exceptional cases, and never against the G-SII, O-SII or systemic risk buffers.
Read against paragraph 424, the German threshold asks for more than the EBA minimum. An institution whose stressed ratios stay above TSCR would be eligible for the no-P2G option in that paragraph; under the German method it can still receive P2G unless it also clears the 500 basis point margin. My reading is that BaFin has used the paragraph 424 discretion to set a national hurdle with headroom above TSCR. The EBA’s June 2026 report on simplifying stacking orders uses the term “hurdle rates” for this kind of comparison between a stressed CET1 ratio and TSCR or the overall capital requirement, and treats the option not to set P2G as something the current framework already accommodates. We covered that report in our piece on the EBA stacking-orders report and prudential reporting.
EBA/GL/2026/06, which applies from 1 January 2027, carries the same principles into new paragraph numbers: paragraph 343 (TSCR breach test and the option not to set P2G), paragraph 345 (simplified stress tests for non-Category 1 institutions), paragraph 347 (two-year determination) and paragraph 348 (maximum stress impact). SREP documentation for the 2026 cycle cites EBA/GL/2022/03; the renumbering matters from the 2027 cycle onwards.
How the Erhebungsbogen displayed an indicative P2G
The completion instructions build the threshold into the workbook. On the sheet “(A2) ST-GuV-Kapital”, rows 54 to 57 carry the institution’s SREP overall requirements, TSCR and TSLRR, pre-filled by the supervisor. Column 3 holds the requirements valid on 31 December 2025, column 8 any different requirements that only take effect in the first projection year, 2026 (Tz. 61). The institution confirms the pre-fill through a drop-down in row 60 or overwrites values it considers wrong, and on that basis rows 58 and 59 display the positive P2G and leverage ratio P2G expected to result.
The cut-off in Tz. 61 deserves attention. The form is designed to reflect TSCR and TSLRR changes ordered with final effect in the SREP under Section 6c(1) sentence 1 numbers 1 and 6 in conjunction with Section 6b KWG, taking account of EBA/GL/2022/03, after the supervisory pre-fill and no later than 29 May 2026. A P2R decision that became final after that date falls outside what the form was built to capture, and the published documents do not say how supervisors treat it.
Because the line is TSCR plus 500 basis points, a stale TSCR in rows 54 to 57 moves the line itself. FAQ 13 of the Q&A list (29 April 2026) sets out the handling: where an institution considers a pre-filled SREP requirement wrong, it overwrites the value, selects “Nein” in the drop-down in row 60, column 3, and records the reason in the comments field of the sheet. No advance notice to the supervisor is required.
The indicative figure also carries two explicit reservations in Tz. 41: adjustments to values during the supervisory data-quality review, and discretionary case-by-case decisions by the supervisor. The number in row 58 can therefore still move before any P2G is communicated. At the zero end of the range the position is simpler. BaFin’s statement at the press conference was that every institution could see while filling in the form whether it receives P2G, and that where no own funds are recommended, the process ends there.
For institutions above zero, the published documents leave three things open: how the final P2G amount is calibrated, how the capital conservation buffer offset in paragraph 435 is applied nationally, and when the individual communications go out. At the press conference BaFin announced that it will shortly publish a supervisory communication (Aufsichtsmitteilung) that describes the process in more detail and addresses technical questions.
What the LSI stress test 2026 measured
The scenario came from the ECB, which gives national supervisors a common scenario for LSI stress tests derived from the systemic risks the European Systemic Risk Board identified for EU financial markets (results presentation, slide 6; Tz. 35, footnote 3). Bundesbank and BaFin translated it very conservatively into risk parameters, especially for credit risk and inflation effects, pointing to the geopolitical situation when the test started, including the Iran conflict and an oil and gas price shock.
| Three-year cumulative shock for Germany | LSI stress test 2026 | LSI stress test 2024 |
|---|---|---|
| Real GDP | -6.5% | -6.3% |
| Unemployment rate | +4.5 pp | +4.0 pp |
| HICP | +11.4% | +13.6% |
| Residential property prices | -8.8% | -28.9% |
| Commercial property prices | -32.9% | -30.4% |
| DAX | -44.1% | -54.6% |
| Credit spread, BBB-rated NFCs | +154 bp | +201 bp |
Source: results presentation of 24 September 2026, slide 7.
Institutions simulated their full profit and loss account over three years from a 31 December 2025 starting point under a static balance sheet: maturing business is rolled over into identical new business at nominal value and the conditions then prevailing, and moving assets from the liquidity reserve into fixed assets is not allowed (Tz. 16, 36 and 37). The test has five parts (Tz. 38). A capital sheet brings the P&L, own funds and hidden reserves together, fed by separate modules for net interest income, credit risk, market risk and the loss-free valuation of the banking book under IDW RS BFA 3.
The shocks are prescribed in Table 1 of the completion instructions. In the net interest income module the stress path lifts the short end most, by 1.73 percentage points at one month or less in 2026 against 0.76 at ten years. In credit risk the supervisor translates the macro scenario into PD and LGD paths directly in the form, with no institution-side calculation. Market risk applies sovereign spread increases from 37 basis points for AAA to 204 basis points for BB and below, spread increases on other interest-bearing positions from 85 to 320 basis points, and value changes of -50.6% on open equity positions and on participations outside the network, -22.0% on open real estate (fund) positions and -17.7% on shares in affiliated companies and network participations.
The remaining P&L lines follow fixed rules. Staff and other administrative expenses are indexed by 75% of the scenario inflation rate (Tz. 60), a uniform 30% tax rate applies (Tz. 54), and net interest income in the adverse scenario is capped at the higher of the 2023 to 2025 average and the 2025 figure, multiplied by 100% (Table 3). Fee income is cut by 20%, other operating income by 37% and current income from equities and participations by 44%, each applied to a positive 2023 to 2025 average.
On results, the aggregate CET1 ratio starts at 18.4% and reaches its low point of 14.6% in the worst year, a depletion of 3.8 percentage points against 3.7 in 2024. Across 2025 to 2028, net interest income adds 7.7 percentage points, while credit risk takes 3.9, market risk 3.1 and other P&L items 4.3, leaving 14.8% at the end of the horizon; the worst year is usually, but not always, the third one, which explains the 0.2 point gap (slide 17). The English press release attributes the decline mainly to “provisions for counterparty credit risk and market risk”; for the credit component, the German slides call the module Adressrisiko and show the driver as loan loss provisions, led by loans secured on commercial real estate and loans to corporates. Loans secured on residential property make up 35.2% of the risk volume but contribute little, because their simulated default probabilities are lower than for commercial real estate. The supervisory cap limited projected net interest income only slightly (slide 20).
The survey half of the return does not feed P2G
The information request had two parts (Tz. 1). Part A.1 was a survey on earnings, Part A.2 the stress test for the SREP. The survey asked for plan data under a dynamic balance sheet plus three supervisory interest rate scenarios under a static balance sheet, an ad hoc parallel shift of +200 basis points, a constant curve and -100 basis points, over 2026 to 2028 (Tz. 21 and 23).
FAQ 6 (17 April 2026) settles how far the survey reaches. Its results are analysed and flow into ongoing supervision, but unlike the stress test results they do not enter the Eigenmittelempfehlung. An optimistic plan in Part A.1 therefore has no route into the P2G figure. The two parts can also rest on different data: FAQ 7 allows internal management reporting systems for the historical P&L in the survey sheet even where the result differs from the capital sheet, which is anchored in the adopted annual financial statements (Tz. 45).
The survey findings still say something about capital plans. Institutions expect return on assets to rise from 0.43% in 2025 to 0.64% in 2028 and plan an aggregate CET1 ratio of 19.1% in 2028 against 18.4% today, while about one in five plans a falling CET1 ratio. The presentation adds that past profitability plans were too optimistic and that the rate expectations in the plans underestimate current rate developments, and the press release notes that recent months were not yet fully reflected in plan figures collected in the second quarter.
What institutions submitted, and through which channel
Participation covered German credit institutions under Section 1(1) KWG supervised directly by BaFin together with the Bundesbank (Tz. 2). Several boundaries change the answer on scope. Significant institutions under direct ECB supervision were excluded (slide 9). Tz. 2 also excluded small and medium-sized investment firms under Section 2(16) and (17) WpIG, housing enterprises with savings facilities, institutions covered by Section 53b or 53c KWG, institutions in orderly wind-down, central counterparties under Section 2(9a) KWG and Bausparkassen, and the Bundesbank hub carries a separate Q&A list for a Bausparkassen stress test dated 26 June 2026. Institutions that had applied for the waiver under Section 2a(1) KWG ran the survey and the stress test on a consolidated basis, using the supervisory rather than the commercial-law consolidation scope (Tz. 4).
The completed workbook was due by 29 May 2026 through the Bundesbank’s NExt portal (Tz. 8 and 9). Excel files embedded in PDF documents could not be accepted, and the Excel file itself was not to carry an extra password or other encryption. The file name followed a fixed pattern, LSI.P.LSIST_Erhb.GEBERNR.20251231.Vx.xlsx, where GEBERNR is the seven-digit Gebernummer without check digit, pre-filled by the supervisor, and Vx is the only part the institution changes, counting versions upwards (Tz. 10). Where an institution considered an additional cover letter necessary, it went in as a separate PDF under LSI.P.LSIST_Begl.GEBERNR.20251231.Vx.pdf, and an optional Depot A ISIN/WKN list under LSI.P.LSIST_DptA.GEBERNR.20251231.Vx.xlsx.
The date component catches institutions with a financial year that does not end on 31 December. FAQ 4 confirms that “20251231” stays in the file name for them too; only the version counter moves.
Quality assurance ran in three stages (Tz. 12). Before submission, the institution worked through the “Datenqualität” sheet, which flags entries against four checks: missing values, whether an entry is a number, the relation of two values, and signs and restrictions. A flagged entry the institution considered correct needed a short comment in the “Eventuelle Anmerkungen” field of the relevant sheet; unexplained flags lead to a request for resubmission. Bundesbank and BaFin then ran their own plausibility review and a benchmarking round, with reports returned through NExt. Only one submission is foreseen, and a resubmission on supervisory request is limited to the issues raised (Tz. 11).
The workbook itself was locked. Changes to its structure trigger a resubmission request, yellow cells were for input, grey cells held calculations, pink cells were optional, and beige cells in five sheets carried supervisory pre-fills that turn violet once changed (Tz. 14). Institutions are obliged to check those pre-filled values for correctness where relevant.
The general proportionality solution and what it trades away
Tz. 41 opened a lighter route. An institution qualified if, on 31 December 2025, it was a small and non-complex institution (SNCI) under the CRR and either its total assets were below EUR 1 billion or its leverage ratio, measured before retained earnings, was at least 12%. Supervisors could bar particular SNCIs from the route or open it to non-SNCIs with total assets below EUR 1 billion. Eligibility was shown in row 1, column 4 of the sheet “(A2) ST-Befreiung RK”, and the institution opted in through the drop-down in row 1, column 5.
Opting in reduced the mandatory cells to those listed in Table 2 and moved the capital effects of every risk category into an automatic calculation. Tz. 41 states expressly that the indicative P2G in rows 58 and 59 applies under the proportionality solution as well, so the lighter route does not take an institution out of the P2G screen. The choice was optional, and an institution that had selected it for its on-time submission could switch to full completion only once, with notice to the supervisor by 22 June 2026 and a resubmission by 29 June 2026. Separately, Tz. 42 allowed exemptions for single risk categories where the relevant reference amount stayed below a set share of total assets, with specific thresholds for SNCIs.
The saving was material. At the press conference BaFin said about half of the participants could claim the exemption from completing all forms, that the number of data points fell by up to a third against 2024 for every institution, and that those able to use the proportional solution saved up to two thirds.
The cost sits in Table 3. Under the proportionality solution, net interest income for the stress years is the 2025 figure carried forward with a 17% haircut; under full completion it comes from the institution’s own projection in the net interest income sheet, subject to the cap described above. Because the capital effects feed the indicative P2G automatically, I read the route choice as shaping that figure, and an institution whose repricing profile would hold up well under a full projection gave some of that away by taking the flat haircut. Table 2 adds a smaller lever in the other direction: under the proportionality or exemption route, optional market risk cells, where filled, could only reduce the capital depletion.
Pre-filled values inherited from COREP and IRRBB reporting
Much of the capital sheet leans on regular reporting. The assignment of P&L contributions follows the reporting references printed in the form, principally Formblatt 3 of the RechKredV and COREP (Tz. 45), and the risk-weighted exposure amount for counterparty credit risk under Article 271 CRR corresponds to COREP template C 34.02, row 0110, column 0200 (Tz. 55). Our guide to COREP templates and requirements covers where those cells come from.
The banking book valuation sheet “(A2) ST-BFA3” goes further. For institutions using the proportionality or exemption route, its beige cells are pre-filled from IRRBB supervisory reporting (Tz. 103). FAQ 11 (29 April 2026) documents the mapping: the ratio of the change in economic value of equity to the worst scenario comes from template J 01.00, row 0020, column 0010, and cash flows come from the behaviourally modelled templates J 05.00.b, J 06.00.b and J 07.00.b, falling back to the contractual versions where only those were reported. The supervisor made a separate Excel file with the formulas available on the Bundesbank’s stress test page. Background on those templates is in our article on IRRBB under the EBA guidelines.
The consequence runs through to P2G. A misreported IRRBB cash flow or a stale COREP value travels into the stress test through the pre-fill, and from there into the indicative figure, unless the institution catches it. Tz. 103 requires institutions to check the pre-filled BFA 3 values, overwrite significant deviations and explain each overwrite in the sheet’s comments field.
After 24 September: follow-up under the current guidelines
The supervisors’ message on the weaker end of the distribution was direct. They are taking particular note of the institutions the stress test flagged and will take timely supervisory measures where necessary. Institutions flagged in 2024 were supervised closely afterwards, and most of them have since raised their own funds ratios, which the press release gives as one reason fewer institutions came under pressure this time.
For institutions that do receive P2G, EBA/GL/2022/03 sets how it sits in the capital stack. P2G is added on top of the overall capital requirement (paragraph 436), is to be met with CET1 capital (paragraph 439), and own funds held for P2G cannot be used to meet any element of the overall capital requirement (paragraph 440). Under paragraph 428(a), an existing P2G is to be reassessed whenever new supervisory stress test results are available. The EBA 2027 EU-wide stress test runs on its own methodology and templates for the banks in its sample; German LSIs outside the ECB’s direct supervision were assessed through this national exercise.
None of the published documents says whether the national method will change when EBA/GL/2026/06 applies on 1 January 2027.
Frequently Asked Questions
The pre-filled SNCI status in our form was wrong. Could we still reach the proportionality solution?
Only through the supervisor. FAQ 13 lists the SNCI status in row 2, column 1 of “(A2) ST-Befreiung RK” and the eligibility flag in row 1, column 4 among the few pre-filled cells the institution cannot change. The institution selects “Nein” in the drop-down in row 17, column 1 and contacts the supervisor early through a questionnaire in NExt; the supervisor then decides and, where needed, supplies a corrected form. Footnote 10 of Tz. 41 also lets supervisors open the route to non-SNCIs with total assets below EUR 1 billion.
Our financial year does not end on 31 December. Which reference dates applied?
With prior approval from the Bundesbank Hauptverwaltung, all reference dates in the request could be shifted by the deviating months so that full annual slices are shown, and the last balance sheet date is entered in the “Information” sheet (Tz. 5). The file name keeps 20251231 regardless (FAQ 4).
Two savings banks completed their legal merger in May 2026. One return or two?
Where the legal merger was completed by the 29 May 2026 deadline, the forms go in on a consolidated basis after prior notice to the Hauptverwaltung. Separate returns remain only where a consolidated submission is not possible, for example because the technical merger is still outstanding. Historical values of the merged institutions are shown consolidated on a best-effort basis, and the survey reference dates do not change (Tz. 3).
Does the TSCR plus 500 basis point line also decide the leverage ratio P2G shown in row 59?
The published threshold is expressed against TSCR, and none of the sources reviewed states an equivalent margin for P2G-LR. Paragraph 424 of EBA/GL/2022/03 treats the two separately: P2G-LR protects against a breach of the total SREP leverage ratio requirement (TSLRR), and the option not to set it depends on whether TSLRR is expected to be breached. Row 59 is best read on its own terms.
Does holding less capital than the P2G amount restrict distributions?
Section 6d(4) KWG answers this directly. While an institution meets its Pillar 1 requirements, its additional own funds requirement under Section 6c, the combined buffer requirement and any leverage ratio buffer requirement, not fully covering the Eigenmittelempfehlung triggers none of the restrictions in Section 10i(1a) to (3) and Section 10j(2) and (3) KWG. Article 104b(6) CRD contains the parallel rule for the restrictions under Articles 141 and 141b CRD.
A pre-filled BFA 3 value is wrong because we filed a correction after the reporting date, and the cell is locked. What then?
FAQ 23 (22 May 2026) covers this case for row 13 of “(A2) ST-BFA3”. A short note in the comments field on the loss-free valuation of the banking book plus “Nein” in the drop-down in row 44, column 1 is enough, and the resulting data-quality flag can be ignored for submission. Where the pre-filled value differs from the value actually relevant, the supervisor analyses whether a newly pre-filled form is needed and, in that case, contacts the institution promptly.
Were Bausparkassen measured against the same threshold?
Bausparkassen were excluded from this information request (Tz. 2), and the Bundesbank hub lists a separate Q&A list for their stress test. The sources reviewed for this article do not state whether the TSCR plus 500 basis point threshold applies to that exercise.
Related Articles
- EBA Revised SREP Guidelines: What EU Banks Must Review in ICAAP, ILAAP and Pillar 2 Capital: the changes EBA/GL/2026/06 brings to SREP capital and liquidity assessments from 1 January 2027.
- EU bank capital framework simplification: what the EBA stacking-orders report means for prudential reporting teams: the June 2026 EBA report and why it keeps P2G as a separate layer.
- COREP Reporting Explained: Templates and Requirements: the COREP template set, remittance timing and common errors that also surface in stress test pre-fills.
- Interest Rate Risk in the Banking Book (IRRBB): EBA Guidelines and CSSF Expectations for Luxembourg Banks: the IRRBB framework, shock scenarios and reporting behind the J templates.
- EBA 2027 EU-Wide Stress Test: What Prudential Reporting Teams Must Track: the simplified 2027 EU-wide methodology and its link to regular supervisory reporting.
Key Takeaways
- Reconcile the TSCR in the latest final SREP decision with rows 54 to 57 of the last accepted Erhebungsbogen version: the P2G line is that TSCR plus 500 basis points.
- Any P2R or TSCR change that became final after 29 May 2026 is outside what the form was built to capture; raise it with the Hauptverwaltung before relying on the indicative figure.
- File the accepted LSI.P.LSIST_Erhb version together with the NExt data-quality and benchmarking reports as the audit trail for rows 58 and 59.
- Treat a positive figure in row 58 as provisional until the supervisor communicates P2G; data-quality adjustments and case-by-case decisions can still move it.
- Keep EBA/GL/2022/03 as the cited basis in 2026 SREP documentation and switch references to EBA/GL/2026/06, section 7.6 (paragraphs 340 to 355) and, for how P2G is communicated, paragraph 448(e), for the 2027 cycle.
- Build any communicated P2G into the capital plan, the risk appetite framework and the recovery plan in CET1 terms, as paragraph 439 of EBA/GL/2022/03 expects.
Sources and References
- BaFin, 2026 LSI stress test: Banks’ and savings banks’ capital buffers robust, press release, 24 September 2026: bafin.de
- Deutsche Bundesbank, press release on the results of the 2026 LSI stress test, 24 September 2026: bundesbank.de
- Deutsche Bundesbank and BaFin, Ergebnisse des LSI-Stresstests 2026, presentation, 24 September 2026: PDF
- BaFin, Pressekonferenz zum LSI-Stresstest 2026 von BaFin und Deutscher Bundesbank, speech by BaFin’s Chief Executive Director of Banking Supervision, 24 September 2026: bafin.de
- BaFin, LSI-Stresstest 2026, announcement, 30 March 2026: bafin.de
- Deutsche Bundesbank, LSI-Stresstest 2026 hub page (documents and Q&A process): bundesbank.de
- Deutsche Bundesbank and BaFin, LSI-Stresstest 2026: Institutsübergreifendes Auskunftsersuchen, Ausfüllhinweise und methodische Vorgaben, 27 March 2026: PDF
- Deutsche Bundesbank and BaFin, “Fragen und Antworten”-Liste zum LSI-Stresstest 2026, status 19 June 2026: PDF
- Kreditwesengesetz (KWG), Section 6b: gesetze-im-internet.de
- Kreditwesengesetz (KWG), Section 6d (Eigenmittelempfehlung): gesetze-im-internet.de
- Directive (EU) 2019/878 (CRD V), inserting Article 104b into Directive 2013/36/EU (CRD): EUR-Lex
- EBA, Guidelines on common procedures and methodologies for SREP and supervisory stress testing, EBA/GL/2022/03, Final Report, 18 March 2022 (section 7.7.1, paragraphs 423 to 442): PDF
- EBA, Guidelines (revised) on common procedures and methodologies for SREP and supervisory stress testing, EBA/GL/2026/06, Final Report, 26 June 2026 (section 7.6, paragraphs 340 to 355; section 9.3, paragraph 448(e), on communicating P2G): PDF
- EBA, press release on the revised SREP Guidelines, 26 June 2026: eba.europa.eu
- EBA, Report on simplifying the stacking orders of the EU prudential and resolution framework, June 2026: PDF
Carrying the 2026 LSI result into the 2027 SREP cycle
The document that matters now is the last accepted version of each institution’s LSI.P.LSIST_Erhb file, with the TSCR in rows 54 to 57 and the indicative P2G and P2G-LR in rows 58 and 59. The open item is any TSCR change that became final after 29 May 2026, and the next fixed date is 1 January 2027, when EBA/GL/2026/06 replaces EBA/GL/2022/03 as the EBA text behind P2G decisions.
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.
