What it is
The Expectations for Banks is the Single Resolution Board's central policy statement on what makes a bank resolvable in practice. Published in 2020 and phased in through the end of 2023, it translates the directive's requirement to be resolvable into a concrete, operational set of capabilities that banks within the SRB's remit are expected to develop and evidence. It is a policy and guidance document, not a piece of legislation, and it does not create legal obligations in the way a directive article does; rather, it operationalises the resolvability framework and gives banks a common reference for what supervisors will look for.
Structure
The document is organised around several dimensions of resolvability, commonly grouped into areas such as governance, loss-absorbing and recapitalisation capacity, liquidity and funding in resolution, operational continuity and access to financial market infrastructures, information systems and data, communication, and separability and restructuring. For each area it describes the capabilities a bank should have in place — for example, the ability to run a bail-in playbook, to produce timely valuation data, to estimate liquidity needs in resolution, and to preserve access to critical services and FMIs. The expectations were introduced progressively so that banks could build capabilities over a defined transition period.
Legal basis
The Expectations for Banks should be cited as SRB guidance rather than as a legal article. Its legal foundation lies in the resolvability and impediment-removal provisions of the Bank Recovery and Resolution Directive (2014/59/EU), principally Articles 15 to 17, which require authorities to assess resolvability and to require the removal of substantive impediments. The Single Resolution Board draws its mandate to plan for and enhance resolvability from the SRM Regulation (806/2014). The document elaborates how those statutory duties are met in practice; it does not itself constitute a directive provision.
Practical relevance
For banks, the Expectations for Banks is effectively the working checklist against which resolvability is assessed and tested: capabilities that fall short can become deficiencies or impediments to resolvability requiring remediation. It underpins resolvability testing, since the capabilities it describes are what dry-runs and deep-dives verify. For investors and analysts, it provides a transparent framework for understanding what supervisors mean by a resolvable bank. Because it is guidance that has been phased in and continues to be refined, its detailed application evolves and can differ across institutions.