Domestic

European Communities (Cross Border Payments) (Amendment) Regulations 2025 published

On 1 September 2025, the European Communities (Cross Border Payments) Regulations 2010 (S.I. No. 183/2010) were amended by the European Communities (Cross Border Payments) (Amendment) Regulations 2025 (S.I. No. 419/2025). The amendments give further effect to the EU Cross Border Payments Regulation (Regulation (EU) No. 2021/1230) by:

• requiring the Central Bank of Ireland (CBI) to monitor and ensure compliance with the EU Cross Border Payments Regulation by persons providing currency conversion services at an ATM or at a point of sale
• creating summary and indictable criminal offences for failure by a person providing currency conversion services at an ATM or at a point of sale to comply with Articles 4(1), 4(3), 4(4) or 4(7) of the EU Cross Border Payments Regulation (which relate to currency conversion charges for card-based transactions)

CBI calls for sandbox applicants

On 23 September 2025, the CBI opened applications for its second ‘Innovation Sandbox Programme’, the theme of which is “Innovation in Payments”.

The ‘Innovation Sandbox Programme’ for 2026 aims to foster innovative solutions that deliver safer, faster and more inclusive payments for households and businesses, while giving the CBI early insight into emerging risks and supervisory questions. It will address the following overarching themes:

• inclusive access to the digital economy - how can everyone confidently engage in the digital economy
• frictionless and transparent money movement - how can payments be made seamless, transparent and efficient to benefit consumers and businesses
• resilient and secure payments - how can payments be strengthened to reduce fraud, ensure integrity and enable faster, safer and more accessible payments
• safe integration of emerging payment technologies - how can new technologies be safely adopted while protecting consumers and maintaining system-wide security and stability

The application window closes at 5pm on 10 November 2025.

European

EBA consults on draft technical package for reporting framework 4.2 and new DPM 2.0 glossary

On 5 September 2025, the European Banking Authority (EBA) published a draft technical package for version 4.2 of its reporting framework, marking a key milestone in the transition to the DPM 2.0 standard and the introduction of a fully enhanced glossary.

Key elements include:

• Completion of the new DPM 2.0 glossary, which now applies across the entire reporting framework. This glossary streamlines terminology and improves consistency in reporting requirements, in accordance with the EBA’s June 2024 roadmap for implementing DPM 2.0.
• Draft technical package for release 4.2, which contains validation rules, DPM, and XBRL taxonomies. It includes the following:
  • comprehensive revision of the implementing technical standards (ITS) on resolution planning
  • new reporting requirements under the Capital Requirements Regulation ((EU) No 575/2013) (CRR) and the Capital Requirements Directive (2013/36/EU) (CRD) in the Common Reporting Framework (COREP)
  • updates to the ITS for the identification and transmission of information on minimum requirements for own funds and eligible liabilities (MREL), by resolution authorities to the EBA
  • changes to supervisory benchmarking for market risk

This draft publication aims to support reporting entities in preparing for the upcoming changes ahead of the final release scheduled for November 2025, which may include possible corrections coming from the revision of the technical package by various stakeholders.

EBA publishes final ITS on framework for reporting MREL under BRRD

On 12 September 2025, the EBA published its final report on draft ITS under Article 45j(2) of the Bank Recovery and Resolution Directive (2014/59/EU) (BRRD), amending the Commission Implementing Regulation (EU) 2021/622 to amend the framework for reporting MREL decisions by resolution authorities.

The amendments introduce a semi-annual reporting cycle, replacing the current annual submission and improve the reporting of discretionary elements applied by resolution authorities, such as adjustments to subordination thresholds and internal MREL decisions at sub-consolidated level. Additional changes streamline data fields, remove simplified reporting for liquidation entities and align the framework with Directive (EU) 2024/1174.

The ITS have been submitted to the Commission for adoption after which they will be published in the Official Journal of the EU. The ITS are expected to apply from 31 December 2025 and are accompanied by a revised Annex I (reporting template) and Annex II (instructions).

EBA issues revised list of ITS validation rules

On 15 September 2025, the EBA published a revised list of validation rules in its ITS on supervisory reporting, highlighting those which have been deactivated either for incorrectness or for triggering IT problems.

The EBA states that data submitted by competent authorities in accordance with the ITS should not be formally validated against the set of deactivated rules.

The EBA also published a small validation package including a micro taxonomy package and DPM VR deactivation updates scripts, which are needed from release 4.0, for each deactivation exercises, to deactivate rules in taxonomy and in DPM in a consistent manner.

ECB launches consultation on harmonised supervisory approach to legacy NPEs at small banks

On 15 September 2025, the European Central Bank (ECB) launched a public consultation on a draft guideline for a harmonised supervisory approach to the coverage of legacy non-performing exposures (NPEs) held by less significant credit institutions (LSIs).

The draft guideline addresses NCAs as the direct supervisors of LSIs, focusing on ensuring sound risk management and consistent supervisory standards, while allowing NCAs to exercise supervisory discretion within the Pillar 2 framework.

The ECB will use the information submitted by LSIs to support its oversight role and promote consistency across euro area supervision. The approach will be phased in over a period from 31 December 2025 to 31 December 2028 in line with transitional arrangements set out in the draft guideline.

The consultation closed on 27 October 2025.

Legislation to further postpone the FRTB standards by an additional year published in the Official Journal

On 19 September 2025, Commission Delegated Regulation (EU) 2025/1496 was published in the Official Journal of the EU, amending the CRR to implement a postponement by one additional year, until 1 January 2027, the date of application of the prudential market risk framework under Basel III, i.e. the fundamental review of the trading book (FRTB).

Credit institutions must continue to apply the pre-FRTB market risk framework under CRR until 1 January 2027.

EBA issues technical advice on the performance of the EU covered bond framework

On 23 September 2025, the EBA published its technical advice on the performance of the EU covered bond framework following a call for advice (CfA) from the Commission for the purposes of their mandates under Article 31 of the Covered Bond Directive ((EU) 2019/2162) (CBD).

The CfA requested the EBA to assess the performance of the current EU covered bond framework, the relevance and the design of a potential third-country equivalence regime, the feasibility of introducing a dual recourse-like instrument to support SME financing, the role of green covered bonds and ESG risks in cover pools.

Following its assessment, the EBA considers the framework broadly fit for purpose and issued the following recommendations for further enhancing the framework:

• enhancing harmonisation by further aligning national frameworks to reduce market fragmentation, while preserving the flexibility of the principle-based approach under the CBD
• protecting investors by strengthening safeguards and improving transparency across all national frameworks to better serve investors
• simplifying and streamlining the EU legal framework by aligning the CBD more closely with the Capital Requirements Regulation
• expanding the scope of the framework by introducing a third-country equivalence regime

EBA announces rising application of AI in EU banking and payments sector

On 25 September 2025, the EBA published a factsheet setting out AI use cases and market trends following a survey of EU banks.

Use cases identified:

• profiling or clustering of clients or transactions
• optimisation of internal processes
• creditworthiness assessment and credit scoring
• AML/CFT and fraud detection
• customer support
• risk modelling.

Market trends include:

• 92% of EU banks are currently deploying AI, and 8% are pilot testing or discussing AI use cases
• 55% of surveyed banks are using general-purpose AI or agentic AI in consumer-facing processes, while just over 22% are using general-purpose AI or agentic AI for regulatory reporting
• the identified benefits of AI include improvements in productivity and efficiency of staff, optimisation of processes and ability to enhance customer interactions

EBA launches its 2025 EU-wide transparency exercise

On 29 September 2025, the EBA launched its 2025 EU-wide transparency exercise with the aim to enhance transparency and market discipline in the EU financial system. The exercise complements banks’ Pillar 3 disclosures under the Capital Requirements Directive and provides market participants with consistent and comparable information on the condition of EU banks.

The 2025 exercise will disclose data of over 100 EU banks on their capital positions, financial assets, risk exposure amounts, sovereign exposures and asset quality. The data will cover the period from the third quarter of 2024 to the second quarter of 2025. The results will be published at the beginning of December, together with the EBA’s risk assessment report. Alongside the dataset, the EBA will provide interactive tools that allow users to explore and compare data across time, countries and individual banks.

Official Journal of the EU contains corrigendum on calculation of eligible liabilities and the transitional regime

On 29 September 2025, a corrigendum to Commission Delegated Regulation (EU) 2024/895 was published in the Official Journal of the EU, amending Delegated Regulation (EU) 2015/63 as regards the calculation of eligible liabilities and the transitional regime.

The corrigendum inserts a new annex into the Commission Delegated Regulation which outlines the procedure for calculating the annual contributions of credit institutions payable to their resolution authority.

Date published: 29 October 2025

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.