European Banking Authority (EBA) 2025 work programme

On 2 October 2024, the European Banking Authority (EBA) outlined its work programme for 2025, focusing on the continued implementation of the EU banking package (Capital Requirements Regulation (CRR) III / Capital Requirements Directive VI) and the enhancement of the Single Rulebook, which was also a priority in 2024.

Additionally, the EBA will take on new responsibilities, including overseeing ICT third-party service providers and supervising issuers of significant asset-referenced and e-money tokens. With various evolving risks on the horizon, the following five strategic priorities have been set for 2025:

Priority 1: Implementing the EU banking package and enhancing the Single Rulebook

• Prioritise Basel III reforms: The EBA will prioritise the timely implementation of outstanding Basel III reforms in the EU, ensuring that banks are better prepared for future crises and maintaining the stability of both the European and global financial systems. This will include strengthening the regulatory framework through more risk-sensitive approaches to determining capital requirements for credit, market and operational risk.
• Complete CRR/CRD package: The negotiations for the CRR/CRD package, concluded in 2023, include over 140 mandates to develop regulatory standards, guidelines and reports. The EBA’s regulatory products will help create a robust framework and level the playing field across the EU single market. In the first half of 2025, the EBA will respond to two calls for advice from the Commission: one concerning the role of non-EU institutions in the EU banking market and another on insolvency benchmarking.
• Incorporate proportionality: Ensure that regulatory products and guidance reflect proportionality, reducing compliance costs without compromising prudential objectives. This is particularly important for small and medium sized banks.
• Focus on ESG mandates: Will address ESG-related mandates as part of the sustainable finance strategy, including risk management, disclosures, stress testing, and developing a framework for systemic monitoring ESG risks.

Priority 2: Enhancing risk-based and forward-looking financial stability for a suitable economy

• Interest rate impact: The EBA will focus on the impact of changing interest rates on both the real economy and the banking sector, particularly in light of high inflation and potential credit tightening due to risk-averse behaviour.
• Geopolitical and economic risks: It will adjust it approaches to assess challenges in the banking sector, including cyber-resilience, in response to heightened geopolitical risks and unstable economic conditions. These efforts will need to be sustained for the foreseeable future.
• ESG risk monitoring: It will continue developing the EBA’s ESG risk monitoring framework to efficiently track ESG risks in the banking sector. This includes monitoring transition and physical risks, as well as market developments related to sustainable products.  
• Stress tests and climate analysis: The EBA will utilise insights from the 2023 EU-wide stress test and the 2024 scenario analysis to inform financial and ESG risk monitoring and supervisory priorities. It will develop regular climate stress tests and guidelines or institutions climate stress tests, incorporating lessons learned and expanding top-down elements.  
• Data infrastructure enhancement: Enhance the EBA’s data infrastructure and launch a data portal as part of the EU’s supervisory data strategy, contribution to more effective data-driven supervision.

Priority 3: Enhancing data infrastructure and launching the data portal

• Enhance data strategy: The EBA will improve the acquisition, compilation, utilisation, and dissemination of regulatory data, strengthening analytical capabilities
• Leverage EUCLID platform: enable data flows and provide high quality, curated data and insights to stakeholders, expanding the dissemination platform to new data sets
• Expand reporting framework: It will also integrate entities under the scope of DORA and MiCAR into the EBA’s reporting framework and develop ESG-related data and metrics.
• Implement DPM standard 2.0: In 2025, the EBA will finalise its implementation of the Data Point Model (DPM) standard 2.0 and methodology, ensuring the data dictionary is aligned with future reporting and digital processing challenges. The EBA will also use Digital Regulatory Reporting tools to produce reporting frameworks, developed jointly with EIOPA.
• Reduce reporting burden: Align with the EC’s initiative to cut down reporting by 25%, enhancing efficiency, data sharing and standardisation.  

Priority 4: Starting oversight and supervisory activities for DORA and MiCAR

• DORA and MiCAR implementation: The EBA, alongside other European Supervisory Authorities, expects to deliver policy mandates related to the Digital Operational Resilience Act (DORA) and Markets in Crypto Assets Regulation (MiCAR) by 2025. These efforts will address the digital risk aspect of the Single Rulebook and provide a regulatory framework for crypto-assets. DORA applies from January 2025, and MiCAR from mid-2024 to early 2025.
• Oversight of ICT third-party providers (TTPs): For DORA, the ESAs will, for the first time, determine the scope of ICT third-party providers (TTPs) by designating Critical TTPs. The EBA will start oversight activities as Lead Overseer, supported by a new IT system and in-house training
• Supervision of crypto-assets: Under MiCAR, the EBA will enhance its readiness to supervise issuers of significant Asset Reference Tokens and Electronic Money Tokens by extending staff training and organising workshops with National Competent Authorities (NCAs). This will also include developing supervisory policies, procedures and IT capabilities.
• Funding and recruitment: DORA and MiCAR tasks are funded by fees from relevant entities. Recruitment of fee-funded resources depends on the number of entities charged and the sufficiency of funds.

Priority 5: Developing consumer-oriented mandates and ensuring a smooth transition to the new AML/CFT framework.

• Transition to AMLA: The EBA will retain its Anti-Money Laundering/Counter Financing of Terrorism (AML/CFT) mandate until 31 December 2025 and continue its transition plans to the new EU AML authority, AMLA.
• Support for new AML/CFT framework: The EBA will response to the European Commission’s call for advice on the new AML/CFT framework, support competent authorities’ changeover plans, and ensure effective corporation with AMLA.
• Focus on financial conduct and consumer protection: Protecting consumers in the financial sector remains a top priority for the EBA. It will continue focusing on consumer protection mandates, further developing its approach to the conduct of financial institutions. This will include ensuring access to financial services, and addressing consumer protection mandates under MiCAR and the Credit Services and Credit Purchases Directive.
• Monitoring financial innovation: The EBA will also monitor financial innovation in areas such as crypto-assets, tokenisation, and new financial products, identifying areas where additional regulatory responses may be needed. It will support the Commission on digital finance topics, including the digital euro and BigTech in finance.
• Support for digital finance: The EBA, along with ESMA, EIOPA and the EC will continue to support the EU Supervisory Digital Finance Academy (SDFA) to strengthen supervisory capacity in digital finance
• Payment services and deposit protection: The EBA will also begin delivering mandates under the revised Deposit Guarantee Schemes Directive, Payment Services Directive and others, with a focus on preventing fraud.  Over forty-five mandates are expected to be developed.