El coste invisible de la estabilidad financiera (II)

In the previous installment of this column, it was noted that the European Central Bank (ECB) and Spanish banking associations AEB, CECA, and UNACC had submitted their proposals for streamlining the banking regulatory framework by the end of 2025. The ECB presented 17 recommendations, while Spanish banking associations put forward a catalog of 24 measures. As one year has passed since those proposals were made, it is worth examining what they have in common rather than focusing on the details of each proposal.

The first common point of agreement is the most technical. Regulators require banks to maintain, in addition to the minimum capital, additional "buffers" to absorb losses during stressful periods. In Europe, these buffers have multiplied, forming a more complex structure than what was initially proposed by Basilea, the international benchmark standard.

The ECB suggests reducing the number of buffers to just two, while Spanish banking associations are also calling for the removal of the systemic risk buffer, which they deem redundant. Both parties also agree that small and simple entities (EPyNC) are burdened with a uniform regulatory attire designed for global banks and seek a review of the asset threshold that grants access to a lighter regulatory regime.

Requiring the same standards from a systemically important bank as from a local non-systemic entity provides no additional safety, only increased cost for the latter.

The second area of agreement, perhaps the one with the greatest consensus, is the information that banks submit to their supervisors. Both parties advocate for a straightforward principle that is currently not being upheld: each piece of data should be reported only once. The ECB proposes an integrated system among authorities, while Spanish banking associations provide concrete examples, such as duplicate resolution reports in different templates or the MREL (the passive buffer for absorbing losses) being declared twice.

Nobody today defends that a single piece of data should travel through multiple channels to reach the supervisor.

The third point concerns the institutional architecture. The ECB proposes reinforcing the "Single Rulebook," the common regulatory body for all entities in the Banking Union, and giving precedence to regulations over directives, which run the risk of being "interpreted" differently in each country. Spanish banking associations translate this into specific requests, such as reviewing the Consumer Credit Directive under "the same rules, the same standards."

The shared diagnosis is that fragmentation between countries can be as costly to competitiveness as the regulatory burden itself. Both documents differ in degree: the ECB sets principles, while Spanish banking associations translate these into concrete numbers and measures. This combination may be the suitable recipe to move forward: the regulator provides the diagnosis, and the sector offers the roadmap.

If both parties transform this consensus into a concrete timetable of reforms, 2027 could be the year when simplification moves from a declaration of intentions to become normative reality (principle of proportionality achieved).