Review of the EU Macroprudential Framework for the Banking Sector / March 2022ContentsForewordKey concepts1Introduction2Systemic risks in the EU banking system over the next decade3Enhancing the EU macroprudential banking framework3.1Macroprudential capital buffers3.2Risk weight measures4Broadening the regulatory perimeter4.1Borrower-based measures4.2Systemic liquidity4.3Bank-like activities of non-banks5Macroprudential tools to address hybrid risks in the next decade5.1Systemic cyber risks5.2Climate-related financial risks6Cooperation in a broader regulatory and institutional contextReferencesAnnexBox A1Elements of a harmonised macroprudential risk weight article forreal estate exposuresBox A2Proposal for including BBMs in EU legislationImprint and acknowledgementsContents 12361115152731313942464648525561616369 Review of the EU Macroprudential Framework for the Banking Sector / March 2022Foreworddeal with failing banks had this turned out to be necessary.Work is ongoing to fully implement internationally agreed reforms and to complete the broaderregulatory reform agenda.This notably includes the full and faithful implementation of thefinalisation of the Basel III agreement as well as the completion of Capital Markets Union and BankingUnion. The reform agenda strives to make the financial system more stable, more efficient, and morereliable. This often comes in the form of restrictions, and hence at a cost to financial institutions. Butthis is a cost well worth paying as it ensures that our financial system remains resilient when facedwith unexpected shocks and does not amplify economic crises when these shocks occur.Financial stability remains one of the foundations on which to build the European Union ofthe future.It allows the financial system to serve European households and businesses and thusto contribute to sustainable economic growth across the EU. We should not be complacent,particularly at the present times. Increased indebtedness across the economy, elevated assetprices remain key vulnerabilities and cyber-attacks that are increasing in frequency andsophistication pose a risk. These and other vulnerabilities and risks need to be addressed such thatthe financial system can support the economic recovery from the pandemic and the twin green anddigital transitions of our economies.This is hence the right time to review whether our macroprudential toolkit for banksfunctions as we want it to, in light of the recent experience and of what might happen in thefuture.The banking sector remains at the core of the financial system in the European Union. Thepresent ESRB Concept Note discusses the main challenges to be addressed and sets out what inthe ESRB’s view needs to be done to ensure that our macroprudential rules for banks remain fit forpurpose and future proof. It is designed to inform and feed into the Commission’s review of themacroprudential framework.Christine LagardeChair of the ESRBForewordChristine Lagarde, Chair of theEuropean Systemic Risk Board 2Large-scale and swift policy intervention in the European Unionand abroad helped stabilise the economy.This included fiscalpolicy, labour market policy and monetary policy measures. Theywere complemented by measures targeted at the financial system toensure a sustained flow of financing to households and businesses.The reforms to the regulatory framework for banksimplemented after the global financial crisis and euro areasovereign debt crisis helped avoid a financial crisis.Enteringthe COVID-19 pandemic, banks were funded with more and better-quality equity to absorb unexpected losses. They also retained moreliquid assets to meet funding liquidity shocks. And resolutionframeworks were in place offering more options than in the past to Review of the EU Macroprudential Framework for the Banking Sector / March 2022Key concepts1.The economic and social costs of financial crises are large. The aim of macroprudential policyis to reduce the probability and impact of such crises. The benefits of this only accrue overtime, can seem abstract and are spread out across all stakeholders, while implementationcosts are felt immediately and sometimes born by only a few stakeholders. This can lead to aninaction bias, whereas an effective macroprudential policy framework must foster prompt anddecisive policy action.2.The enhanced regulatory framework for banks, including macroprudential tools, served the EUwell during the COVID-19 crisis. However, it remains to be tested through a whole financialcycle and in the absence of significant intervention by public authorities. Full, timely andconsistent implementation of the outstanding Basel III reforms is crucial to furtherstrengthening the framework. Resilient banks – both in terms of quality and quantity of capital –are better lenders, as they can continue to provide credit in times of crisis to businesses andhouseholds that are solvent, but liquidity-constrained.3.The macroprudential toolkit contributed to resilienc