EBA Consults New SREP Guidelines: Revisions Reflect Regulatory Developments, Including DORA And ESG, As Well As Lessons Learned

October 2025 – On 24 October 2025, the European Banking Authority ("EBA") published a consultation paper on revised guidelines on common procedures and methodologies for the supervisory review and evaluation process ("SREP") and supervisory stress testing (EBA/CP/2025/21). The consultation period will last three months, until 26 January 2026. The revised SREP Guidelines are expected to apply from 1 January 2027.

New SREP Guidelines will integrate recent legislative changes and address lessons learned

Since the issuance of the initial SREP Guidelines in 2014 and its subsequent revisions in 2017 and 2021, the European regulatory framework has significantly advanced. Mainly, the CRR III/CRD IV banking package, the Digital Operational Resilience Act ("DORA"), several Environmental, Social and Governance ("ESG") requirements, and the provisions on interest rate and credit spread risk in the banking book have further elevated the regulatory landscape in the EU. With the new revised SREP Guidelines, the EBA intends to reflect all these changes while at the same time addressing lessons learned since the nearly ten years of SREP implementation. This will be the third revision of the SREP Guidelines.

The new revised SREP Guidelines will consolidate all relevant SREP provisions into a single, comprehensive framework and integrate relevant new aspects. They also repeal the separate information and communications technology ("ICT") SREP Guidelines (EBA/GL/2017/05), as the ICT risk assessment has been integrated into the revised guidelines. Further, they fulfil the EBA mandates to issue guidelines on SREP for third-country branches and to operationalise the requirements where banks become bound by the output floor.

Overall, the revised SREP Guidelines aim at strengthening supervisory convergence, improving clarity, and enhancing SREP proportionality, sequencing, and effectiveness. The EBA also intends to set a focus on a risk-focused supervisory approach and simplification.

Summary of key amendments

The revised SREP Guidelines do not alter the general SREP framework and its major components and institutional categorisation. Rather, new elements are introduced to further refine the individual SREP elements. The EBA chose this approach over establishing separate chapters to reflect the strong interlinkage of the new elements with existing SREP elements.

The most significant amendments of the revised SREP Guidelines can be summarised as follows:

• The minimum frequency for the SREP assessment of small and non-complex institutions will be extended from three to five years if certain conditions are met, mainly, a stable, low-risk profile, and the level of flexibility regarding the granularity of the assessment will be increased.
• The business model analysis will in the future also consider ICT and ESG risks.
• How institutions address ICT and ESG risks in their overall risk management framework and the respective knowledge and skills of the management board will also be a part of the assessment of internal governance and institution-wide controls.
• Operational resilience (including ICT risks) and ESG risks will therefore become a regular part of the SREP. This should enable a holistic assessment of the ability to deliver critical or important functions in the event of disruptions as well as a more comprehensive and forward-looking supervisory approach.
• Market risk arising from transfer pricing arrangements will be captured under Pillar 2 requirements.
• Provisions on credit spread risks in the banking book ("CSRBB") will be added to the assessment of risks to capital, and the outcome of the CSRBB assessment should be reflected in a combined IRRBB/CSRBB score.
• The interaction between Pillar 1 own funds requirements and Pillar 2 own funds requirements, as well as the output floor, will be reflected in the SREP capital assessment.
• Special SREP requirements for third-country branches will be incorporated. A main focus in this regard will be reliance on the third-country parent company and sufficient independence in governance and risk management. This also includes maintaining sufficient substance in the respective EU member state.
• A section dedicated to the communication of the SREP assessment will be introduced that determines which elements of information must at minimum be communicated by the competent authorities to the institutions regarding the outcome.
• A high-level escalation framework for supervisory measures will be introduced. This shall promote clarity and consistency as well as predictability and transparency for institutions. However, the steps outlined will not have to be followed in a strict sequential manner and can in any case not alter the existing supervisory powers granted under applicable local legal frameworks.

Initial assessment of the revision

The revision of the SREP Guidelines comes after the European Central Bank ("ECB") simplified and reviewed its SREP for directly and indirectly supervised banks in the EU Single Supervisory Mechanism, following the launch of reforms in 2024. The ECB aims at a simpler, more flexible supervisory process with a shorter SREP timeline. However, the revised SREP Guidelines will still have to be reflected in the reviewed ECB SREP.

With regard to the impact of the revised SREP Guidelines, it can already be said that institutions may face challenges resulting from the broader scope, increased expectations, and tighter integration of new regulatory frameworks. They will need to adapt to the new expectations, especially operational resilience and sustainability. The incorporation of ICT and ESG risks into the SREP assessment implies that institutions will have to further strengthen their ICT governance and ESG risk frameworks. However, institutions still struggle with fragmented IT systems as well as data availability and quantification of ESG risks. Additional resources will need to be allocated. On the other hand, smaller institutions may benefit from enhanced proportionality.

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