On 18 September 2020, the European Banking Authority (EBA) published an opinion addressed to the European Commission to raise awareness as to the opportunity to clarify certain issues relating to the definition of credit institution in the upcoming review of the Capital Requirements Regulation (CRR) and the Capital Requirements Directive IV.

The opinion illustrates that divergences remain in the interpretation of elements of the notion of ‘credit institution’, despite its definition being embodied in the CRR. The EBA opinion argues that the following terms within the definition should be clarified – ‘business of which’, ‘deposits’, ‘other repayable funds’ and ‘public’.