Authorities
Banking resolution in Europe is run by a network of institutions: the Single Resolution Board and national resolution authorities decide and execute resolution in the banking union, the ECB supervises and determines failure, and the EBA, the FSB and non–banking union authorities complete the framework.
Who decides what, in order
A banking-union failure passes through five hands. Each step is a separate legal decision by a different institution.
- 1Failing or likely to failECBThe supervisor determines that the bank is failing, or likely to fail, and that no private or supervisory action would prevent it.
- 2Public interest assessmentSRBThe resolution authority asks whether resolution serves the public interest, or whether normal insolvency would do just as well.
- 3Resolution schemeSRBIf it does, the SRB adopts a scheme: which tool, which liabilities are written down or converted, and on what terms.
- 4EndorsementCommissionThe Commission — and, on discretionary points, the Council — endorses or objects within 24 hours.
- 5ExecutionNRAThe national resolution authority executes the scheme under its own law, usually over a weekend.
The institutions
From the global standard setter down to the authority that signs the transfer order.
Single Resolution Board
Decides whether a failing banking-union bank is resolved, and how.
The Single Resolution Board (SRB) is the central resolution authority of the banking union, established in 2015 by the Single Resolution Mechanism Regulation. It is directly responsible for the significant banking groups supervised by the ECB and for cross-border groups: it drafts their resolution plans, sets their MREL requirements, and adopts the resolution scheme when a bank fails.
The SRB also owns the Single Resolution Fund (SRF), an industry-financed fund that can support a resolution after shareholders and creditors have absorbed losses equal to at least 8% of total liabilities and own funds. Its first — and so far only — full resolution was Banco Popular Español in June 2017.
ECB Banking Supervision
Declares a bank failing or likely to fail — the trigger for everything else.
The European Central Bank, through the Single Supervisory Mechanism (SSM), directly supervises the significant institutions of the banking union. In the resolution sequence its decisive role is the “failing or likely to fail” (FOLTF) determination: the supervisory judgement that triggers the SRB’s assessment of whether resolution is in the public interest. The ECB’s list of significant institutions also defines the core of this site’s entity universe.
National resolution authorities
Execute the schemes the SRB adopts, and resolve the banks outside its remit.
Each member state designates a national resolution authority (NRA) — among them FROB in Spain, the ACPR in France, the Bundesanstalt für Finanzdienstleistungsaufsicht in Germany and the Bank of Italy. Within the banking union the NRAs execute the schemes the SRB adopts, using national implementations of the BRRD toolkit, and are directly responsible for planning and resolving the less significant institutions outside the SRB’s remit.
European Banking Authority
Writes the technical standards that make the framework operational.
The European Banking Authority (EBA) writes the technical standards and guidelines that make the resolution framework operational: the criteria for resolvability, the methodology behind MREL, the templates for reporting and disclosure, and regular monitoring reports on MREL stocks and shortfalls. Its transparency exercises are one of the sources for the disclosed metrics on this site.
Bank of England
Runs the UK regime under the Banking Act 2009, which predates the BRRD.
The Bank of England is the United Kingdom’s resolution authority under the Banking Act 2009, which predates and informed the EU framework. It sets MREL for UK banks and building societies, publishes resolvability assessments, and executed the 2023 resolution of Silicon Valley Bank UK through a sale to HSBC. After Brexit the UK regime evolves independently, but remains structurally close to the BRRD.
FINMA
Supervises and resolves Swiss banks, including the gone-concern requirements.
The Swiss Financial Market Supervisory Authority (FINMA) is the resolution authority for Swiss banks, including the gone-concern requirements applying to the systemically important groups. The 2023 rescue of Credit Suisse — a state-facilitated merger with UBS including the write-down of AT1 instruments outside a formal resolution — remains the defining recent test of the Swiss regime.
Financial Stability Board
Sets the global standards — Key Attributes, TLAC and the G-SIB list.
The Financial Stability Board (FSB) sets the global standards the European framework implements: the 2011 Key Attributes of Effective Resolution Regimes and the 2015 TLAC term sheet for global systemically important banks, transposed into EU law through the CRR. It also maintains the annual G-SIB list that determines which groups carry TLAC requirements.
European Commission — DG FISMA
Drafts the legislation and endorses every SRB resolution scheme.
The Commission’s Directorate-General for Financial Stability, Financial Services and Capital Markets Union drafts the legislation behind the framework — BRRD, SRMR and their reviews, including the pending crisis management and deposit insurance (CMDI) reform — and endorses or objects to each SRB resolution scheme before it takes effect. See Regulation for the legal texts.