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Financial Services Regulation and Compliance - Banking and Payments April 2026

Financial Regulation Advisory

Financial Services Regulation and Compliance - Banking and Payments April 2026

The Council of the EU published the final compromise texts of the PSD3/PSR legislative proposals and the legislative acts to reform the EU’s bank crisis management and deposit insurance framework were published in the Official Journal of the EU.

Thu 30 Apr 2026

6 min read

European

EBA consults on revised guidelines on exposures to shadow banking entities under CRR

On 9 April 2026, the European Banking Authority (EBA) launched a public consultation on draft revised guidelines on limits on exposures to shadow banking entities under Articles 395(2) and (2a) of the Capital Requirements Regulation (Regulation (EU) 575/2013) (CRR). The draft guidelines aim to align with the updated EU large exposures framework and to support sound risk management and governance practices across credit institutions, including new criteria for identifying shadow banking entities.

In particular, the proposals update the basis for limits by moving from eligible capital to Tier 1 capital, while maintaining existing governance requirements and approaches to setting exposure limits, and removing the 0.25% materiality threshold. The EBA is also seeking feedback on current practices and the potential impact of quantitative limits on exposures to shadow banking entities.

EBA report on banks’ dry run testing of recovery plans

On 13 April 2026, the EBA published a report comparing how banks test the implementation of their recovery plans through “dry runs”. The analysis confirms that dry runs are an effective tool for strengthening the operationalisation of recovery plans and enhancing institutions’ crisis readiness, improving their ability to respond to stress situations in a timely and credible manner.

While approaches and levels of maturity vary across banks, the EBA found that most institutions recognise the value of dry runs and use lessons learned to improve their recovery planning frameworks. The report highlights the importance of maintaining regular and robust testing practices and continuing to refine dry run methodologies, particularly in light of ongoing work on simulation exercises and developments under the crisis management and deposit insurance framework.

EBA report on benchmarking of diversity practices in the banking sector

On 23 April 2026, the EBA published a report on benchmarking diversity practices in the banking sector based on 2024 data. The EBA calls on institutions to promote more balanced gender representation and on competent authorities to continue assessing diversity and gender pay gap practices as part of supervisory reviews.

The report finds that gender imbalance persists at senior management level, with women under‑represented in key leadership roles. It also highlights uneven implementation of diversity policies across institutions, and a continued gender pay gap at senior level. The EBA further notes a positive correlation between gender balance and financial performance and indicates it will continue to monitor developments in this area.

PSD3/PSR: Final compromise texts published

On 23 April 2026, the Council of the EU published final compromise texts of the legislative proposals for a Third Payment Services Directive (PSD3) and Payment Services Regulation (PSR), following provisional agreement with the European Parliament in November 2025.The Council also issued an ‘I’ item note recommending approval by the Committee of Permanent Representatives with a view to reaching agreement at second reading.

The proposals require formal adoption by the Council and the Parliament before publication in the Official Journal of the EU. For payment institutions, e‑money institutions and in‑scope credit institutions, the final texts provide important clarity on the move towards a more harmonised regulatory model, enabling firms to progress from high‑level assessments to detailed gap analysis and implementation planning.

ECB response to Commission consultation on EU banking sector competitiveness

On 14 April 2026, the European Central Bank's (ECB) Governing Council published its response to the European Commission’s targeted public consultation on the competitiveness of the EU banking sector, launched in February 2026 to inform a forthcoming Commission report. The ECB’s Governing Council response builds on the Governing Council’s proposals to simplify EU banking rules which were published in December 2025.

CMDI reform package published in the Official Journal

The following directives and regulation reforming the EU bank crisis management and deposit insurance framework (CMDI), proposed by the European Commission in April 2023, were published in the Official Journal of the EU on 20 April 2026:

European Parliament publishes Annual Report on the Banking Union (2025)

On 24 April 2026, the European Parliament published its Annual Report on the Banking Union (2025), reviewing developments during 2025. The Parliament urges swift completion of the Union, notably a credible European Deposit Insurance Scheme, full implementation of Basel III, effective anti‑money‑laundering arrangements and progress on the Savings and Investments Union and a digital euro.

The Parliament welcomes the crisis management and deposit insurance framework reforms, highlights risks from non‑bank financial intermediaries, crypto‑assets and sovereign-bank links, and demands robust supervision, adequate MREL and a mutualised Single Resolution Fund with an ESM backstop. It also calls on EU institutions to advance regulatory convergence, strengthen resilience and ensure taxpayers are not exposed to bank failures.

CRD: EBA publishes final guidelines on supervisory independence under CRD

On 29 April 2026, the EBA published its final report on guidelines on supervisory independence of competent authorities under the Capital Requirements Directive, establishing harmonised minimum standards to prevent and manage conflicts of interest among staff and governance members. The guidelines cover requirements such as pre‑employment, annual and ad hoc declarations, trading restrictions, disposal of financial instruments, and cooling‑off periods, as well as rules on appointments and tenure, with the aim of ensuring transparency, proportionality and consistent application across authorities.

EBA streamlines its guidelines on connected clients to align with new EU legislation

On 29 April 2026, the EBA published a decision to partially delete provisions of its guidelines on connected clients (EBA/GL/2017/15) following the entry into force of new EU legislation. The changes reflect Commission Delegated Regulation (EU) 2024/1728, which introduces binding technical standards on the identification of groups of connected clients. As these rules now apply directly across the EU, certain provisions of the guidelines have been removed to ensure consistency and avoid duplication.

Date published: 30 April 2026

This publication provides an overview of certain legal and regulatory developments that may be of interest to certain entities. It does not purport to provide analysis of law or legal advice and is strictly for information purposes only.