欧元体系对欧盟委员会关于欧盟银行业竞争力的定向磋商的回应

Contents 1Executive summary22Euro area banks92.1Resilient banks: the backbone of the EU financial system92.2The competitiveness of euro area banks132.3Financial fragmentation and lack of scale are key constraints oncompetitiveness143The Single Market and the banking union193.1The banking union203.2Impediments to cross-border banking integration213.3Proposals to support deeper banking sector integration223.4Reducing regulatory fragmentation234The complexity and effectiveness of the regulatory framework264.1Recommendations and concrete actions undertaken264.2General assessment274.3The prudential framework284.4Capital instruments324.5The macroprudential framework324.6Resolution framework364.7Proportionality374.8Reporting38 Annex 1 – HLTF report on simplification of the European prudentialregulatory, supervisory and reporting framework Annex 2 – Notes and comments60 Executive summary The Eurosystem welcomes the European Commission’s targeted consultationand supports an ambitious reform agenda to enhance the competitiveness ofEU banks, while preserving the resilience and stability of the financial system.Amid increasing geopolitical and geoeconomic fragmentation, the Commission’sconsultation represents a timely opportunity to consider holistically what is necessaryto establish a truly integrated European banking market, which is a prerequisite forachieving the long-term economic objectives of the Union. The continuedfragmentation of EU banking markets acts as a brake on European banks scaling up,realising economies of scale and competing both within and outside the EU, andlimits private risk-sharing. To break the current deadlock, the Eurosystem callsstrongly for synchronised progress on key banking union components, takingconcrete steps towards the finalisation of a European Deposit Insurance Scheme(EDIS), with a clear timetable for implementation, and fostering deeper capitalmarkets by progressing on the savings and investment union. This also requiresstrengthening the crisis management and deposit insurance framework which shouldproceed in coordination and synchronisation with deepening banking integration viamore harmonised rules and the removal of barriers to the free flow of capital andliquidity in cross-border groups. These steps should be accompanied by adequatesafeguards promoting resilience holistically for credit institutions and theirsubsidiaries, branches and consolidated groups, including through fair and timelytransfers of resources within groups, particularly in times of stress. These necessaryinitiatives should have full regard to the diversity of European banks, which theEurosystem recognises as a source of systemic resilience. The report of the High Level Task Force on Simplification (HLTF) – endorsed bythe ECB’s Governing Council in December 2025–forms the basis and is anintegral part of the Eurosystem’s response to the European Commission’stargeted consultation on the competitiveness of the banking sector.Theproposals in both reports complement each other, and should be read in conjunction.The HLTF report is annexed to this document. The ECB is implementing a four-pronged agenda to increase the efficiency,effectiveness and risk-based focus of European banking supervision.Theagenda includes (i) the ongoing reform of the Supervisory Review and EvaluationProcess (SREP); (ii) implementing several operational initiatives to achieve gains ineffectiveness and efficiency across supervisory activities as part of the “next-levelsupervision” project; (iii) promoting a unified supervisory culture within the SSM; and(iv)assessing supervisory effectiveness. The principles underpinning the HLTF recommendations are essential toensure that any proposal to simplify the EU prudential framework will beeffective in promoting the sustained competitiveness of euro area banks.Those principles are as follows (i) Resilience should be maintained – any proposal tochange the EU prudential framework should preserve current levels of resilience; (ii) effectiveness in meeting prudential objectives needs to be maintained –microprudential, macroprudential and resolution authorities should be able to meettheir respective objectives in an effective manner and capture all relevantdimensions of risk; (iii) European harmonisation and financial integration should befostered – proposals shall take a European perspective and aim to foster moreharmonisation across Member States in areas where a lack of harmonisation is asource of complexity or inconsistency; and (iv) international cooperation should beupheld – international standards and multilateral cooperation are crucial, and alljurisdictions should ensure full, timely and faithful implementation of Basel III. By delivering on its mandate to maintain price stability and contribute to thesafety and soundness of the European banking system and the stability of thefinancial system, the Eurosystem is fostering the conditions for euro areabanks’ to be competitive.The debate o