ECB Guidance | European Central Bank

July 15th 2026

ECB clarification on ICAAPs and ILAAPs and respective package submissions

No description available.

AI Analysis

On 10 February 2025, the ECB published a clarification paper tightening expectations on ICAAP and ILAAP design and, critically, on how and when related information must be submitted in the SREP cycle. The core compliance impact is a shorter annual submission deadline, a two‑step (annual plus continuous) reporting model, and more formalised governance, forward‑looking planning, and capital distribution expectations that must be demonstrably embedded in banks’ ICAAP/ILAAP frameworks and Board‑level oversight.

What Changed

- Introduced a two‑step ICAAP/ILAAP submission model under the SREP: (1) annual submission of the main “ICAAP & ILAAP package” by 15 March and (2) continuous, year‑round submission of any new or...
Shortened the standard annual deadline for ICAAP/ILAAP information from 31 March to 15 March, reducing the preparation and governance window by roughly two weeks versus prior practice.
Confirmed that the clarifications apply from the SREP 2025 cycle onwards, with a general transition approach for 2025 and limited transitional flexibilities for banks whose internal processes cannot...
Required inclusion of two distinct, concise documents within the annual packages: a “Capital Adequacy Statement” and a “Liquidity Adequacy Statement” reflecting the management body’s formal view on...
Clarified governance expectations around capital and liquidity planning, including regular updates of governance frameworks to reflect external conditions and the submission of a complete risk...

Suggested Considerations

Review existing ICAAP and ILAAP submission calendars and internal governance timelines and formally reset them to ensure core packages can be prepared, approved by the management body, and submitted by 15 March each year.
Design and implement a documented two‑step submission process, including procedures for continuous, year‑round identification, approval and transmission to the ECB of any new or materially updated ICAAP/ILAAP‑relevant documents.
Develop, approve and embed the new Capital Adequacy Statement and Liquidity Adequacy Statement, ensuring they reflect the management body’s signed‑off view on adequacy and are supported by clear references to ICAAP/ILAAP analyses and results.
Update ICAAP and ILAAP governance frameworks to reflect ECB expectations, including explicit roles and responsibilities, escalation paths, periodic reviews triggered by external developments, and Board‑level oversight of capital and liquidity planning.
Compile and maintain a comprehensive risk inventory covering both normative and economic perspectives, and ensure it is aligned with business models, risk appetite frameworks, recovery plans, stress testing programmes and SREP submissions.

Key Dates

15 March (annually from 2025 onward) DEADLINE

- Recurring annual deadline for submission of the core ICAAP and ILAAP packages, including the Capital Adequacy Statement, Liquidity Adequacy Statement, risk inventory, stress testing information and liquidity stressed assumptions template

10 February 2025

- ECB publishes the clarification paper on ICAAPs and ILAAPs and respective package submissions, setting out new expectations on governance, content and submission processes

14 March 2025 DEADLINE

- For the SREP 2025 cycle only, general transition date by which all documents foreseen for annual submission must be provided to the ECB, marking the first application of the new two‑leg submission process and shortened deadline

15 March 2025 DEADLINE

- New general submission date for ICAAP and ILAAP information becomes effective, replacing the former 31 March deadline for annual packages and applying to ICAAP quantifications, ILAAP templates and other annual information

Continuous (from SREP 2025 cycle onward)

- Ongoing, year‑round obligation to submit to the ECB any new or significantly updated ICAAP/ILAAP‑relevant documents, together with a description and justification of changes and their implications for capital and liquidity adequacy

Compliance Impact

Non‑compliance with the revised ICAAP/ILAAP expectations and submission deadlines can trigger SREP findings, higher Pillar 2 capital requirements, restrictions on distributions, and enhanced supervisory scrutiny. Persistent deficiencies in governance, buffers and forward‑looking adequacy assessments may also lead to qualitative measures, remedial action plans, and potential sanctions under the SSM framework.

References

AI-generated analysis. May contain errors or omissions — verify with the original ECB source before acting. Full disclaimer.

Sectors:

Banking & Credit

Topics:

Prudential / Capital Requirements Reporting & Disclosure Senior Managers / Governance

Bank

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🇪🇺 ECB Guidance medium

June 26th 2026

ECB streamlines supervisory guidance to improve clarity and transparency

No description available.

AI Analysis

The ECB has launched a **comprehensive clean‑up and re‑classification of all its supervisory guidance** (guides, reports, letters, methodologies) to streamline content, remove outdated expectations and explicitly underline that these documents are **non‑binding**. This matters for compliance teams because it changes the **reference set of applicable ECB expectations**, clarifies the status of “supervisory guidance” versus hard law, and introduces targeted revisions in key areas such as ICAAP management buffers, internal models, CRR III implementation and licensing processes.

What Changed

- The ECB is conducting a comprehensive review of around 130 supervisory publications (guides, reports, letters, methodologies) to assess their relevance, effectiveness and clarity and to align them...
Approximately 40 supervisory documents have been classified as outdated, superseded or no longer relevant and have been formally discontinued, with the texts remaining accessible but clearly labelled...
The ECB has updated its classification of supervisory guidance documents to emphasise explicitly that they are non‑binding, do not create new legal obligations and do not replace binding EU or...
The Guide to the internal capital adequacy assessment process (ICAAP Guide) will be revised to clarify supervisory expectations on the management buffer, explicitly positioning it as the bank’s own...
The ECB has removed all content on supervisory expectations for the credit conversion factor (CCF) from the Guide to internal models, in anticipation of forthcoming EBA guidelines on CCF, thereby...

Suggested Considerations

Review the ECB press release and associated lists of discontinued publications to identify any ECB guides, reports, letters or methodologies currently referenced in your internal policies, risk frameworks or model documentation that are now labelled as discontinued.
Update internal policy inventories, regulatory mapping and compliance registers to reflect the new classification of ECB supervisory guidance as non‑binding and to distinguish clearly between binding EU/national law and non‑binding ECB expectations.
For banks using the ICAAP Guide, perform a gap analysis of capital planning and management buffer practices against the forthcoming clarified expectations, ensuring internal documentation clearly differentiates management buffers from Pillar 2 requirements and guidance.
For institutions using internal models for credit risk, remove any reliance on the ECB’s former CCF expectations by re‑mapping modelling policies and documentation to forthcoming EBA guidelines on credit conversion factors and to CRR/CRD provisions, once those guidelines are finalised.
For risk and finance functions, review the CVA treatment in internal capital and risk methodologies to verify alignment with CRR III and ensure that internal references to ECB guidance (assessment methodology, materiality assessment) are updated to reflect the removed CVA content.

Key Dates

26 June 2026

- ECB announces the comprehensive review of around 130 supervisory guidance publications, confirms discontinuation of about 40 outdated documents, and signals targeted and in‑depth revisions for the remaining guidance set

Q3 2026 (approx.)

- Revised **Guide to the internal capital adequacy assessment process** is expected to be published “shortly” after the press release, incorporating clarified treatment of the management buffer and its relationship to Pillar 2 guidance

Q3–Q4 2026 (approx.)

- Removal of supervisory expectations on **credit conversion factor (CCF)** from the **Guide to internal models** and the removal of **CVA references** from the **Guide on assessment methodology** and the **Guide on materiality assessment** are implemented as part of the ongoing review and alignment with EBA guidance and CRR III

Q4 2026–2027 (TBD)

- **Public consultations** will be launched on those guidance documents identified as needing substantial revision, ahead of finalising the updated versions

Q1 2027

- Publication of the new **report on good practices in governance and risk culture**, replacing the existing Draft guide on governance and risk culture, following finalisation of the revised EBA Guidelines on internal governance

Compliance Impact

The immediate legal risk is limited because the ECB reiterates that its supervisory guidance is non‑binding and does not create new obligations, but misalignment with updated ECB expectations can materially affect SREP outcomes, Pillar 2 guidance, model approvals and licensing decisions. Failure to update internal frameworks, models and governance practices in line with the revised guidance and EBA/CRR III developments may therefore lead to higher capital guidance, increased supervisory findings, delays in approvals and more intensive supervisory scrutiny.