The 2024 work programme by the EBA

As a result, the EBA points to the ever-increasing number of mandates it is supposed to fulfil as well as to the unchanged number of staff members and resources at its disposal.

Key takeaways

1. 2024-2026 priorities are

Promote and implement an effective and proportionate Single Rulebook;
Foster financial stability in a sustainable economy;
Enable an integrated regulatory reporting system for authorities and market discipline;
Set up and start DORA oversight and MiCAR supervision; and
Increase focus on innovation and consumers and ensure a smooth transition to the new AML / CFT framework.

2. Most noteworthy EBA deliverables for 2024 include (excluding most of the CRR III / CRD VI mandates)

Call for advice on revision of Covered Bond Directive in Q3 2024;
Consultation on draft RTS on the elements to calculate the Business Indicator components (BIC) to be confirmed in 2024;
RTS on FX and commodity risk in the BB – ibid;
Final report on Greenwashing by Q2 2024;
DORA RTS: RTS to specify threat-led penetration testing aspects, RTS to specify elements when sub-contracting critical or important functions and RTS on specifying the reporting of major ICT-related incidents – all Q2 2024;
MiCA level 2 will be concentrated in Q2 2024;
Report on cost and performance of EU structured deposits in 2024 in Q2 2024;
EBA opinion on virtual IBANs by Q2 2024;
EBA RTS on RTS to specify the systemic importance indicators for third-country branches by Q3 2024.

3. Also interesting to note is that the EBA intends to launch a peer review on

Dividend arbitrage trading schemes (cum-ex / cum-cum);
Resilience of deposit guarantee schemes;
ICT risk assessment under the SREP;
Authorisation under PSD2;
Supervision of Pillar 3 disclosures (in 2025);
Supervision of IR in the banking book (in 2025).

In more detail

The 2024 priorities are based on the below five pillars:

Implement the Basel framework in the EU and enhance the single rulebook
Here, the EBA points to uncertainty around the 125 mandates from CRR III / CRD VI.
Monitor financial stability and sustainability in a context of increased rates and uncertainty
Notably, the EBA will assess the need for changes to its stress testing methodology for the 2025 exercise.
Provide a data infrastructure at the service of stakeholders
Develop an oversight and supervisory capacity of DORA and MiCA
Under DORA, the EBA will take part in 13 level-2 mandates, including oversight activities for which it will be assigned the role of Lead Overseer. Under MiCA, the EBA expects to deliver around 20 technical standards and guidelines in 2024. The EBA will also have to be ready by the end of 2024 to supervise issuers of significant asset-referenced and e-money tokens.
Increase focus on innovation and consumers (including access to financial services) while preparing the transition to the new AML/CFT framework
The EBA indicates it expects AMLA to be established in 2024.

The below table provides an overview of the planned regulatory activities:

Capital, loss absorbency and accounting	No specific timeline
Capital, loss absorbency and accounting	Preparation of the report to the EU Commission on completeness and appropriateness of provisions on consolidation Update RTS on own funds and eligible liabilities and RTS on methods of consolidation, where needed GL specifying activities that are a direct extension of banking, activities ancillary to banking and similar activities
Liquidity, leverage and IR risk	TBC
Liquidity, leverage and IR risk	Possible updates of the regulatory products and any additional supervisory guidance as needed following the scrutiny plans and implementation of the regulatory package on IRRBB
Credit Risk	Q1
	2023 benchmarking report on IRB models as well as securitisation and covered bonds Monitoring report on capital treatment of STS synthetics Monitoring report on collateralisation practices
	Q2
	GL on calculation of K IRB for dilution and credit risk + Preparation of 2025 benchmarking portfolios – update of ITS (including aspects related to IFRS 9) Peer review on definition of default + follow-up on peer review on NPEs
	Q3
	GL specifying the terms substantial cash deposits, appropriate amount of obligor-contributed equity, significant portion of total contracts and substantial equity at risk GL specifying the methodology to be applied by institutions when estimating IRB-CCF RTS on criteria that institutions should assign to off-balance sheet items – CP CRR III / CRD VI roadmap Call for advice on revision of Covered Bond Directive
Market, investment firms and services, and operational risk	Q2
	Final RTS on extraordinary circumstances for being permitted to continue using the IMA RTS on extraordinary circumstances for being permitted to limit the backtesting add-on GL on the meaning of exceptional circumstances for the reclassification of a position
	Q4
	Call for advice on IFD/IFR ITS on mapping Business Indicator components (BIC) to FINREP RTS establishing a risk taxonomy of OpRisk loss events
	TBC
	RTS on the elements used to calculate the Business Indicator components (BIC) – consultation RTS on adjustments of the BIC – consultation RTS on the calculation of aggregated losses above 750k and unduly burdensome exemption RTS on FX and commodity risk in the BB RTS on the assessment methodology for market risk RTS on the assessment of risk factor modellability under the IMA RTS on backtesting and the P&L attribution test
Market access, governance, supervisory review and convergence	Q2
	Report on the application of gender-neutral remuneration polices by banks & investment firms Report on the application of waivers for remuneration requirements
Recovery and resolution	Q4
Recovery and resolution	Quantitative report monitoring the build-up of MREL resources in the EU Handbook on crisis simulation exercises
ESG supervision and regulation	Q2
	Final report on greenwashing
	Q3
	Annual report on Article 18 SFDR
	Q4
	Treatment of brown and green exposures in Pillar 1 follow-up report
	TBC
	Guidelines on ESG risk management
Innovation and fintech	Q4
Innovation and fintech	Follow up work related to the financial innovation priorities including tokenisation and DeFi, application of AI / ML in financial sectors, digital identity management, including by clarifying supervisory expectations for specific use cases, where deemed necessary
DORA	Q1
	RTS on specifying the elements and components of the ICT risk management framework RTS on the simplified ICT risk management framework RTS to specify the policy on ICT services RTS on criteria for the classification of ICT-related incidents
	Q2
	RTS to specify threat-led penetration testing aspects RTS to specify elements when sub-contracting critical or important functions RTS on specifying the reporting of major ICT-related incidents Guidelines on the aggregated annual costs and losses caused by major ICT incidents Guidelines on cooperation between ESAs and CAs regarding the structure of the oversight RTS to specify information on oversight conduct Feasibility report for centralisation of incident reporting through an EU HuB
MiCA	Q2
MiCA	RTS on information to be submitted in an application for authorisation to issue asset-referenced tokens (ARTs) ITS on information to be submitted in an application for authorisation to issue ARTs GL on the suitability of members of the management body and qualifying holdings (issuers of ARTs and CASPs) (joint mandate with ESMA) RTS on the use of ARTs and EMTs referencing a non-EU official currency as a means of exchange ITS on the use of ARTs and EMTs referencing a non-EU official currency as a means of exchange RTS to specify requirements, templates and procedures for handling complaints by issuers of ARTs RTS on conflicts of interest RTS on own funds and stress testing, RTS on liquidity (reserve of assets of ARTs), RTS on highly liquid financial instruments, RTS on acquisitions of qualified holdings (QHs), RTS on supplemental requirements for issuers of significant ARTs GL on stress testing, GL on recovery plans and GL on redemption plans
Payment services, consumer and depositor protection	Q1
	Assessment of the impact on the EBA of the revision of the EU CCD
	Q2
	Report on cost and performance of EU structured deposits in 2024
	Q3
	Follow-up work on non-bank mortgage lenders and creditworthiness assessment
	Q4
	Technical advice to the Commission on the criteria and factors to be taken into account by the EBA for the purpose of temporarily banning crypto-assets under MiCA
AML/CFT	Q2
AML/CFT	Opinion on virtual IBANs + guidelines on transfers of funds and crypto assets
Reporting and transparency framework	Q2
	ITS on the use of ARTs as a means of payment + ITS on Pillar 3 disclosures – following CRR III changes
	Q3
	ITS on the format and processes for reporting major ICT-related incidents
Risk analysis	Q3
Risk analysis	RTS to specify the systemic importance indicators for third-country branches
Stress testing	TBC
Stress testing	Guidelines on institutions’ climate stress test + joint ESA guidelines on methodologies for climate stress testing
Regulatory impact assessments	TBC
Regulatory impact assessments	Call for advice (to be received) on insolvency benchmarking – as foreseen in CMU action plan

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