We appreciate the EBA initiative to reduce the deadline from four to three months for the application submission to the resolution authorities for ad hoc and general prior permission before the date any of the actions referred in Art. 77 of CRR would be taken.
The EBA decision, highlighting that authorities have gained the necessary experience and are now able to process permissions within a shorter period, addresses practical issues and observed market development. The change provides more flexibility to institutions and improves capital planning.
We encourage the EBA to continue monitoring the development of competences of authorities and possibly re-adjust the period, thereby further reducing the timing for the application to reduce own funds and eligible liabilities instruments.
7 October 2025
EACB responds to EBA draft RTS on the timing for the application to reduce own funds and eligible liabilities
EACB