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Financial Services Regulation and Compliance - Banking and Payments March 2026

Financial Regulation Advisory

Financial Services Regulation and Compliance - Banking and Payments March 2026

Domestically, the CBI published a consultation paper on methodology for calculating contributions to the DGS. At European level, the European Commission initiates infringement proceedings against Member States for failure to transpose CRD VI.

Thu 23 Apr 2026

3 min read

Domestic

Central Bank of Ireland publishes consultation paper on methodology for calculating contributions to the DGS

On 13 March 2026, the Central Bank of Ireland (CBI) published a consultation paper (CP167) on the methodology for calculating contributions to the Deposit Guarantee Scheme (DGS). The CBI is proposing to change the method used to calculate annual contributions to the DGS from the current “flow based” approach to a “stock based” approach, which would take effect from Q3 2026. The new approach would consider each member institution’s cumulative past contributions when deciding whether any further contributions may be required.

The aim of the stock-based approach is to make contribution requests more proportionate for member institutions, now that it the stock based approach is available to use under European Banking Authority (EBA) methodology and now that the DGS fund has reached the minimum target level.

European

EBA publishes final guidelines on capital endowment requirements for third-country branches under CRD VI

On 2 March 2026, the EBA published its final report on guidelines specifying the instruments available for third-country branches (TCBs) for unrestricted and immediate use to cover risks or losses under Article 48e(2)(c) of the Capital Requirements Directive (CRD) as amended by CRD VI. CRD VI introduces a new requirement, effective from 11 January 2027, for non-EEA banks wishing to carry on core banking activities in the EU to establish an authorised branch. The guidelines set out the eligible instruments that TCBs may hold in escrow accounts for resolution and winding-up purposes, including cash, debt securities issued by central governments or central banks and other instruments meeting specified criteria. The guidelines will apply from 11 January 2027.

EBA publishes final report on draft ITS on supervisory reporting of third-country branches

On 5 March 2026, the EBA published its final report on draft implementing technical standards on the supervisory reporting of third-country branches under CRD VI, introducing uniform formats, definitions and reporting frequencies. The EBA noted (among other points) that the first reporting reference date was postponed to 31 March 2027.

European Commission initiates infringement proceedings against Member States for failure to transpose CRD VI

On 27 March 2026, the European Commission (the Commission) announced that it has launched infringement proceedings against 22 EU Member States, including Ireland, for failing to fully transpose CRD VI into national law by the 10 January 2026 deadline.

The Commission has issued letters of formal notice to the Member States concerned, requiring them to notify the Commission of their national transposition measures within two months. In the absence of a satisfactory response, the Commission may proceed to the next stage of the infringement process by issuing a reasoned opinion.

ECB streamlines internal model approval process for banks’ credit risk models

On 30 March 2026, the European Central Bank (ECB) announced changes to its supervisory approach to assessing credit institutions’ internal models for credit risk, shifting from ex ante to ex post assessment to accelerate approvals and reduce operational burden. The reform will allow banks to implement model changes without running old and new models in parallel, subject to prudential safeguards.

From 1 October 2026, credit institutions will be permitted to implement material model changes shortly after submitting a complete application, conditional on confirmation by internal control functions that regulatory requirements are met. Where changes lead to lower risk weights, capital relief will be subject to a temporary floor of 98% of existing risk weights pending completion of targeted ECB on‑site investigations.

In parallel, the EBA published revised regulatory technical standards on the materiality assessment of changes to internal credit risk models, recalibrating criteria to reduce the number of changes classified as material while maintaining supervisory oversight.

Date published: 23 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.