On 15 June 2020, the European Banking Authority (EBA) published a letter it had sent to the European Commission regarding delaying certain technical standards for the risk reduction measures package set out in the CRD V, CRR II, BRRD II and EMIR.

The letter notes that the EU’s risk reduction package gives rise to around 100 new mandates for the EBA under the CRD V, CRR II and BRRD II. The package also provides for the EBA to deliver around 30 reports or sets of monitoring actions designed to support the effective and consistent implementation of the Single Rulebook as well as its supervisory convergence in practice.

The EBA notifies the Commission in the letter that it plans to submit technical standards due to be delivered by December 2019 and June 2020 within the following new deadlines:


  • Article 36(4) – regulatory technical standard (RTS) on software – expected H2 2020.
  • Article 124 – RTS specifying rigorous criteria for the assessment of the mortgage lending value (article 124(1)) and the types of factors to be considered for the assessment of the appropriateness of the risk weights – expected 31 July 2021.
  • Article 164 – RTS specifying conditions to be taken into account when assessing the appropriateness of loss given default values – expected 31 July 2021.
  • Article 132a (4) – RTS on collective investment undertakings – expected Q1 2021.
  • Article 430(7) – Final draft implementing technical standards (ITS) on reporting and disclosures of MREL/TLAC (CRR II / BRRD II) – expected July 2020.
  • Article 430(8) – Cost of compliance study on supervisory reporting – expected H1 2021.
  • Article 430c – Feasibility study on integrated reporting – expected H1 2022.
  • Article 394(4) – RTS on identification of shadow banking entities – expected December 2022.
  • Article 390(8) – RTS on the definition of group of connected clients – expected December 2022.


  • Article 98 (5) – RTS on supervisory shock scenarios for interest rate risk arising from non-trading book activities (IRRBB) – expected March 2022.
  • Article 84(5) – RTS on standardised and simplified methodologies for IRRBB – expected March 2022.
  • Article 84(6) – Guidelines on criteria for internal models for IRBB and credit spread risk from non-trading book activities – expected March 2022.
  • Article 84 – RTS on assumptions for the economic value of equity for IRRBB – expected March 2022.
  • Article 98(5a) – RTS on assumptions for net interest income (NII) for IRRBB – expected March 2022.
  • Article 98(5) – RTS on meaning of large decline for NII for IRRBB –expected March 2022.


  • Article 55(6) – RTS specifying further clarification with regard to the exclusions from contractual recognition of bail-in – expected December 2020.
  • Article 55(8) – ITS on notification to resolution authorities under Article 55 of the BRRD –expected December 2020.
  • Article 71a(5) – RTS determining the contents of the contractual terms required in financial contracts governed by third country law for the recognition of resolution stay powers –expected December 2020.
  • Article 45j(2) – ITS on MREL decisions reporting to the EBA –expected December 2020.


  • Article 11(15) (aa) – RTS Initial Margin Model Validation – now expected June 2021.