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CRR 3 and CRD 6 at the end of the legislative path. What comes next?

CRR 3 and CRD 6 at the end of the legislative path. What comes next?

Newsletter 06/2024

Probably only a few people in the banking sector have not heard of the CRR 3 regulation and the CRD 6 directive. These are revisions of the existing banking regulations, primarily concerning:

  • the completion of the Basel III implementation,
  • strengthening the resilience of the banking sector to ESG risks, and
  • ensuring stronger supervision.

 
The legislative path of these documents was relatively long. The proposals for CRR 3 and CRD 6 were issued already at the end of October 2021. A year later, in the autumn of 2022, the Council of the European Union published its position on these proposals and issued a version referred to as the "general approach." Then, the European Parliament began to discuss the proposals. In the second quarter of 2023, the so-called trilogues (tripartite negotiations on legislative proposals between representatives of the Parliament, Council, and Commission) took place, and in June 2023, a preliminary agreement was reached. By the end of 2023, the texts were approved within the interinstitutional negotiations. At the session of the European Parliament on April 24, 2024, the regulatory proposals were approved, and subsequently, at the end of May, the documents were adopted by the Council and signed. The final step in this legislative process is their publication in the Official Journal of the European Union (OJEU), which can be expected soon. It is worth mentioning that despite a longer legislative process than expected, the original date for the application of most CRR 3 provisions as of January 1, 2025, remains unchanged.
 
One might want to exclaim, "Hooray, it's finally done." However, those who have already looked into the documents know that the end is not here yet. At the end of 2023, the EBA issued a document titled "Roadmap on the implementation of the EU Banking Package." In this document, the EBA itself states that the regulation contains approximately 140 mandates necessary for the actual practical implementation of the banking package. Specifically, 60 RTS and ITS, 29 GL, and 36 reports and opinions. The rest will consist of products related to disclosures, including the EBA Data Hub. Currently, about 17 consultation documents have already been issued, covering various areas of regulation. So, it is not finished yet.
 
The goal of the issued roadmap is to provide clear information on how the EBA will develop mandates to implement the legislation, with the expectation to complete the most important parts before January 1, 2025. The sequence of development of regulatory documents and products will follow their legislative deadlines. Most mandates should thus be completed within 2-3 years after the CRR 3 regulation and CRD 6 directive come into effect.
 
In connection with the new banking legislation CRR 3 and CRD 6, we warmly invite you to our seminar "CRR 3 / CRD 6 in Detail," which will take place on October 1, 2024. Additionally, we can offer you the following:

  • workshop to familiarize participants with the changes in regulatory requirements,
  • regulatory compliance gap analysis,
  • design of an internal methodology for implementing STA in banks currently using IRB,
  • consultations on implementing partial changes (including adjustments to methodologies and models),
  • development of a system for managing ESG risks.