EBA 2026 O-SII List: Which EU Banks Carry an O-SII Buffer

ByOfficer

Last updated: June 2026

An O-SII buffer is the one capital add-on that quietly decides whether your bank can pay a dividend. It sits inside the combined buffer requirement, and the moment your Common Equity Tier 1 ratio falls below that combined requirement, the maximum distributable amount machinery switches on and caps dividends, Additional Tier 1 coupons, and variable remuneration. So when the European Banking Authority refreshes its list of Other Systemically Important Institutions, the question for a reporting team is narrow. Are we on the list, at what rate, and is that rate flowing correctly through COREP and Pillar 3?

On 2 June 2026 the EBA published its updated O-SII list, reflecting the 2025 round of national designations. It names 172 institutions across the European Union, with O-SII buffer rates running from 0.25% to 3% of total risk exposure amount. The EBA’s own framing is that the population stays broadly stable against 2024. Stable in aggregate does not mean stable for every bank, and that gap is where reporting errors hide.

Related reading: our guide to macroprudential buffer stacking.

What the EBA published on 2 June 2026

The 2 June release is the annual refresh of the O-SII population, with a downloadable list and an interactive visualisation tool. The 172 designations and the 0.25% to 3% rate range it records rest on Article 131(3) of the Capital Requirements Directive (Directive 2013/36/EU), read with the EBA Guidelines on the O-SII assessment criteria, EBA/GL/2014/10.

One detail decides how you treat this document. The EBA list is a compilation: it aggregates designations that national authorities have already made and notified, and is not itself the act that binds any single bank. Treating it as your source of record is the first place teams go wrong, because the rate that drives your capital requirement lives in the national decision, not the EBA table.

The EBA does not designate your bank

Article 131(1) of the CRD puts identification in the hands of the competent or designated authority in each Member State, on an individual, sub-consolidated, or consolidated basis as applicable. Article 131(3) sets the criteria those authorities assess: size, importance for the economy of the Union or of the relevant Member State, significance of cross-border activities, and interconnectedness with the financial system. EBA/GL/2014/10 turns those four criteria into a scoring grid of ten indicators, each criterion carrying an equal 25% weight, with each indicator scored against the national aggregate and expressed in basis points.

The guideline sets an automatic designation threshold of 350 basis points. A national authority may move that threshold down to 275 or up to 425 basis points to reflect the distribution of scores in its own banking sector. Above the threshold, designation is effectively automatic. Below it, an authority can still designate on supervisory judgement.

Luxembourg shows how this lands in a real instrument. CSSF Regulation No 25-05 of 28 November 2025 sets a national cut-off of 325 basis points, lower than the EBA’s proposed threshold, and identifies six O-SIIs on the standard EBA methodology using scores as at 31 December 2024, with buffer rates applying from 1 January 2026. BGL BNP Paribas carries a 1.0% buffer; Banque et Caisse d’Epargne de l’Etat, Banque Internationale a Luxembourg, Clearstream Banking S.A., Intesa Sanpaolo Bank Luxembourg S.A., and Societe Generale Luxembourg each carry 0.5%. For how the wider directive lands in national law, see our note on the CRD VI Luxembourg transposition law.

How much capital the O-SII buffer demands

Article 131(5) of the CRD lets the authority require an O-SII buffer of up to 3% of total risk exposure amount, met entirely with Common Equity Tier 1 capital. The same CET1 cannot do double duty: capital used to meet the buffer cannot also count toward the Pillar 1 minimum under Article 92 of the Capital Requirements Regulation or toward the Pillar 2 requirement.

The 3% figure reads like a hard ceiling. It is not. Article 131(5a), inserted by CRD V (Directive (EU) 2019/878), allows a buffer above 3% subject to Commission authorisation. The procedure has a timetable: the ESRB delivers an opinion within six weeks of the notification, and the Commission then has three months to authorise the measure. CRD V also raised the standard cap from the original 2% to 3%, so older guidance citing a 2% maximum is out of date.

A second trap waits for cross-border groups. Where an O-SII is a subsidiary of a G-SII or another O-SII that carries a buffer on a consolidated basis, Article 131(8) caps the subsidiary’s buffer at the lower of two figures: the consolidated group buffer plus one percentage point, or 3% (or the rate the Commission has authorised for the group). Note the word lower: CRD V replaced the earlier higher-of formulation.

Where the O-SII buffer sits in the capital stack

The O-SII buffer is one component of the combined buffer requirement defined in Article 128(6) of the CRD. The combined requirement is the capital conservation buffer (2.5% under Article 129) extended, as applicable, by the institution-specific countercyclical buffer, a G-SII buffer, an O-SII buffer, and a systemic risk buffer. Two interaction rules decide what actually applies.

At group consolidated level, Article 131(14) applies the higher of the G-SII buffer and the O-SII buffer, not their sum. The systemic risk buffer is different. Article 131(15) makes the systemic risk buffer cumulative with the O-SII or G-SII buffer applied under Article 131. When I map the stack, I add the systemic risk buffer on top of the higher of the G-SII or O-SII buffer, not instead of it. The error I watch for is the pre-CRD V higher-of habit, where teams treat the systemic risk buffer and the O-SII buffer as mutually exclusive. They are not. If the sum of the systemic risk buffer rate and the O-SII or G-SII buffer rate would exceed 5%, the Article 131(5a) Commission authorisation route is triggered.

This is not academic. The combined buffer requirement is the line your CET1 ratio is tested against for distributions, so an understated buffer hides a real maximum distributable amount risk. The EBA set out how these layers interlock in the EBA O-SII buffer opinion on combined systemic buffers. And because the buffer is a percentage of total risk exposure amount, the CRR3 output floor phase-in belongs on the same worksheet.

What changes in your COREP and Pillar 3 reporting

The designation does not create a new return. It changes the numbers inside returns you already file. In COREP own funds, the combined buffer requirement and its components are carried as memorandum items in template C 04.00, while the capital ratios tested against that requirement sit in C 03.00. The rate you load must match the national decision, not the EBA aggregate, and not last year’s rate carried forward by habit.

On the disclosure side, the EBA Pillar 3 framework under the current implementing technical standards, Commission Implementing Regulation (EU) 2024/3172, which replaced (EU) 2021/637, surfaces the buffer in two places. Template EU KM1 reports the O-SII buffer at row EU 10a and the combined buffer requirement at row 11. Template EU CC1 carries the G-SII or O-SII buffer requirement at row EU-67a. The first reconciliation I run when a list lands is the national decision against the rate already in the C 04.00 memorandum items, because a mismatch there propagates straight into the published KM1. For the full own funds return, see our COREP reporting guide.

Frequently Asked Questions

Does being on the EBA O-SII list automatically mean a higher buffer?

No. The EBA list records designations; it does not set buffer rates. The buffer is set by the national competent or designated authority under Article 131(5), and a designation can come with a rate as low as 0.25% or no immediate increase at all. The 2026 list reflects a population the EBA describes as broadly stable against 2024.

Who decides whether my institution is an O-SII?

The competent or designated authority in your Member State, under Article 131(1) of the CRD, assessed against the Article 131(3) criteria and scored using the EBA Guidelines EBA/GL/2014/10. In Luxembourg that is the CSSF, acting through a national regulation such as CSSF Regulation No 25-05.

What is the maximum O-SII buffer?

Article 131(5) caps the standard O-SII buffer at 3% of total risk exposure amount. Article 131(5a) allows a higher rate, but only with Commission authorisation following an ESRB opinion. The 3% ceiling replaced the original 2% cap when CRD V took effect.

Do the O-SII buffer and the systemic risk buffer add together?

Yes. Article 131(15) makes the systemic risk buffer cumulative with the O-SII or G-SII buffer. Only the G-SII and O-SII buffers take a higher-of rule between themselves at consolidated level, under Article 131(14). Treating the systemic risk buffer as an alternative rather than an addition understates the combined buffer requirement.

What happens if our CET1 ratio falls below the combined buffer requirement?

The maximum distributable amount restrictions apply, limiting dividends, Additional Tier 1 coupons, and variable remuneration until the buffer is rebuilt. The O-SII buffer is part of the combined requirement that triggers this, which is why an accurate rate in COREP C 04.00 matters beyond the return itself.

Related Articles

Key Takeaways

  • The EBA published its updated O-SII list on 2 June 2026, naming 172 EU institutions with buffer rates from 0.25% to 3% of total risk exposure amount, broadly stable against 2024.
  • The EBA list compiles national designations. The binding act is the national decision under Article 131(1), not the EBA spreadsheet.
  • Designation follows Article 131(3) criteria scored under EBA/GL/2014/10, with a 350 basis point automatic threshold that authorities may set between 275 and 425 basis points.
  • The standard buffer cap is 3% of total risk exposure amount under Article 131(5); a higher rate needs Commission authorisation under Article 131(5a).
  • The systemic risk buffer is cumulative with the O-SII or G-SII buffer under Article 131(15); only G-SII and O-SII buffers take the higher-of treatment between themselves.
  • Report the rate from the national decision in COREP C 04.00 and Pillar 3 templates EU KM1 (rows EU 10a and 11) and EU CC1 (row EU-67a), not the EBA aggregate or a stale prior-year rate.

Sources and References

  • EBA press release, updated O-SII list, 2 June 2026: eba.europa.eu
  • EBA O-SII 2025 interactive visualisation tool: tools.eba.europa.eu
  • Directive 2013/36/EU (CRD), Article 131, on EUR-Lex: eur-lex.europa.eu
  • Directive (EU) 2019/878 (CRD V), amending Article 131: eur-lex.europa.eu
  • EBA Guidelines EBA/GL/2014/10 on the assessment of O-SIIs: eba.europa.eu (PDF)
  • Commission Implementing Regulation (EU) 2024/3172 (current Pillar 3 disclosure ITS): eur-lex.europa.eu
  • Commission Implementing Regulation (EU) 2021/637 (predecessor Pillar 3 disclosure ITS, repealed and replaced by (EU) 2024/3172): eur-lex.europa.eu
  • CSSF Regulation No 25-05 of 28 November 2025 (Luxembourg O-SIIs): cssf.lu (PDF)

Reading the 2026 O-SII List Without Getting Burned

The 2026 update is quiet by design, and that is the risk. A broadly stable population invites teams to copy last year’s rate forward. The discipline that protects you is small and specific. Pull the national designation, confirm the rate against the C 04.00 memorandum items, add the systemic risk buffer on top rather than alongside, and check that EU KM1 and CC1 match your COREP return. Get those reconciliations right and the list is a non-event. Skip them and the first sign of trouble is a maximum distributable amount restriction you did not see coming.

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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