The European Association of Co-operative Banks (EACB) welcomes the opportunity to comment on the EBA’s draft revised Guidelines on internal governance and supports the objective of promoting strong, effective governance across the EU banking sector.
At the same time, the EACB believes the draft would strongly benefit from a clearer and more proportionate approach. Many cooperative banks have simpler structures or operate within integrated networks, making it essential that requirements—particularly those on documentation, responsibility mapping and committee structures—remain scalable and adaptable.
The EACB also stresses the importance of respecting the Level 1 mandate as well as national legislation. The Guidelines should avoid de-facto prescriptive rules that could conflict with national company law or established governance systems, be it one-tier or two-tier boards. Flexibility should be preserved for arrangements like executive chairs where national law permits them and appropriate safeguards exist.
We support improvements to governance frameworks, including risk management, control functions and the three-lines-of-defence model, but caution that new obligations should not introduce disproportionate complexity, for smaller institutions, or cooperative groups relying on shared services.
We welcome the emphasis on risk culture, diversity, and gender-neutral remuneration, and encourage alignment with existing EU legislation to prevent duplication.
Finally, given the scope of changes, the EACB calls for a realistic implementation timeline that allows institutions to update governance frameworks without disrupting operations.