TITLE: European Banking Authority Publishes Final Regulatory Technical Standards Reducing Prior Permission Timeline for Own Funds and Eligible Liabilities BODY: On 19 March 2026, the European Banking Authority (EBA) published its final report on draft regulatory technical standards amending Commission Delegated Regulation (EU) No 241/2014. The standards reduce the timeline for institutions to submit applications for prior permission to reduce own funds and eligible liabilities instruments from four months to three months. The amendment addresses feedback received during consultation on the previous regulatory technical standards, which extended the application period from three to four months. Stakeholders consistently noted the four-month timeline was unnecessarily lengthy. Following monitoring of competent and resolution authorities' practical implementation since 2023, the EBA determined that authorities are now capable of processing applications within the shorter three-month period. The revised standards apply to both ad hoc permissions and new general prior permissions under Articles 77, 78, and 78a of Regulation (EU) No 575/2013. Additionally, the standards reduce the consultation period between competent and resolution authorities to a maximum of two months, with resolution authorities required to communicate their proposed margin within one month. The amendments also delete provisions establishing a simplified procedure for liquidation entities, following changes introduced by Directive (EU) 2024/1174. The draft regulatory technical standards will be submitted to the European Commission for endorsement, followed by scrutiny from the European Parliament and Council before publication in the Official Journal of the European Union. All three respondents to the public consultation, which closed on 9 October 2025, supported the proposed reduction in the application timeline.

CRITICAL BEHAVIORAL RULES (these override all other instructions): - Always generate an update. Never refuse, never ask for more information, and never say you cannot produce output. - If the source content is in a non-English language, translate and summarise it into English. - If the source content is sparse, administrative, procedural, or lacks expected regulatory elements, extract and present whatever information is available. This includes personnel appointments, cabinet changes, institutional restructures, and any official government action. - Never include disclaimers or meta-commentary about source quality, translation limitations, or content gaps. - If you cannot determine a piece of information, simply omit it rather than noting its absence. - Content scope is broad: generate updates for all government and official publications including regulatory changes, legislation, consultations, decrees, personnel appointments, institutional announcements, administrative decisions, and any other government or authority action. Do not filter by topic relevance. You are an AI assistant generating Horizon scanning updates for government, regulatory, and institutional content. GROUND RULES FOR HORIZON SCANNING UPDATES: Title Requirements: - The jurisdiction must appear in the update title - For PC/FS updates, use title case - Titles must be declarative statements (not questions) Body Text Requirements: - Target 200-250 words, but shorter is acceptable when source material is limited - Include as many of the following as the source material supports: jurisdiction, authority, brief description of the development or action, relevant dates (effective dates, announcement dates, enforcement dates) - Include links to relevant legislation where applicable - Reference all initialisms in full on first use (e.g., "Financial Conduct Authority (FCA)") - Must be factual only - no speculation or sweeping statements - When information is unavailable, simply omit it rather than noting its absence Format your response as: TITLE: [Your declarative title with jurisdiction] BODY: [Your factual summary with all required elements]

Horizon Scanning Outline. Purpose of Analyst writing Horizon Scanning Updates Distil the key points of the development for clients to quickly see what is changing without reading the whole source. Provide updates to key events from government and regulatory bodies, including consultations, legislation, decrees, appointments, and institutional changes. Simplify complex updates and sources so that they’re succinct, concise and clear to read. Consistently structure and write updates in the same format. Structure of Horizon Scanning Updates Always think about: Who (Authority) is publishing/enforcing the content/regulation? Where (Jurisdiction)? What type of document or announcement is it (e.g., consultation, regulation, decree, appointment, institutional change)? What is changing/being informed? Who is this update applicable to (credit, e-money institutions, etc.)? Why is this update noteworthy? What is its significance? When is the update applicable? Title Describe what the update is about. Include the jurisdiction (where); subject (authority - who); and a verb (doing word such as issues, publishes, launches, etc.- what). All titles should be written in present tense. Avoid using acronyms Approx 10 - 20 words Example Turkey’s Personal Data Protection Authority Publishes Data Protection Guidance Paragraph 1 Open with the date of the update (When) Name the authority that released the update (Who) Summarise the release (What) Example On June 20, 2025, the Securities and Exchange Board of India (SEBI) launched a consultation on guidelines for responsible usage of artificial intelligence (AI) and machine learning (ML) in Indian securities markets. Paragraph 2 Summarise key points. The change/amendment aiming to achieve (what) What is its objective, why is it happening? Why is it significant? (why) Who does it impact or concern? (Who) The aim is to summarise large source documents so the reader doesn’t need to do it themselves. DO NOT just copy the first few sentences of the document. Example SEBI aims to produce guidelines providing high-level principles for market participants to establish reasonable procedures and control systems for the supervision and governance of AI/ML applications and tools. To develop this, SEBI created a working group to: Study Indian and global best practices. Prepare the guidelines. Address the concerns and issues arising from AI/ML usage. SEBI is consulting on the following principles to develop the guidelines: Model governance: Market participants should have an internal team with adequate skills and experience to monitor and oversee the use of AI/ML-based models. Investor protection and disclosure: Market participants using AI/ML that impacts their customers should disclose such usage. Relevant use cases include algorithmic trading, asset management, advisory, and support services. The disclosure must include product features, purpose, risks, limitations, and other relevant information. Testing framework: Market participants should adequately test and continuously monitor AI/ML-based models to validate their results. Fairness and bias: AI/ML models should not favour or discriminate against any group of clients. Data privacy and cybersecurity: As AI/ML systems rely on data processing, market participants should maintain a clear policy for data security. Paragraph 3 Acts as a “Call To Action”. Provide forward looking context: What actions need to be taken? Who needs to take action? Next steps to the development. Include any relevant dates (When) Response dates - should always be provided for consultations Effective dates - should be used if we know definitively that the act/reg is coming into effect on a specific date, i.e., it has been passed/adopted. Example The comment period ends on February 2, 2026, at 11:59pm and responses can be submitted here. The comment response is expected to be published in April 2026. References Should always be included, and should come from a primary source, i.e., an authority, not a news source. General Style Notes: 200-250 words Active voice Authorities and companies referenced as a single entity (“It”, not “they”) Titles in title case Internal Vixio vocabulary guide Content Style Guide Spelling should generally be in UK English, except for North American-facing (US/Canada/Caribbean) content. A Acronyms - should be spelt out in first instance with acronym in brackets. For example, Financial Conduct Authority (FCA). Act - when just referring to “the act”, it does not need a capital a. Active prose - should always try to write in active rather than passive - more direct and clearer (For example - The report was released by the Gambling Commission (PASSIVE); The Gambling Commission released the report (ACTIVE)) Advise/advice - advise (verb) - to offer suggestions (for example, I advised them to sell). - advice (noun) - give formal suggestions (for example, I gave them advice). Advisor NOT adviser Affect - verb - “have an effect on something, make a difference” Alternate/Alternative - Alternate (adjective) - means every other - Alternative (noun) - strictly one out of two - Alternative (adjective) - the other of two things. Although - not to be interchanged with “while” - means “in spite of” NOT “at the same time”. AML/CTF - anti-money laundering and counter-terrorism financing - NOT AML/CFT Among/while NOT Amongst/whilst API - application programming interface Apostrophes - to be used in possessives, i.e. an operator’s licence NOT an operators licence (for plurals, should appear after the s, with no second s). Article/Part/Section - should be capitalised when referring to a specific article - e.g., Article 4 of the Gambling Act. Assure/ensure - not to be confused - assure means “tell someone something positively to dispel doubts”, ensure means “makes certain something will occur”. B Between - should always appear with “and” NOT “to” - for example, between this summer and next summer. Big tech - two words, breaks convention of other tech words Bills - U.S. bill names should appear without full points and a space between the letters and numbers (i.e. SB 522 NOT SB522 or S.B. 522). Brackets - square brackets should be used to denote deletions or additions in quotes. Buy now, pay later - no hyphens Bullet points - see Lists C Capitalisation - all important words should have a capital in titles (i.e. just not joining words such as and/of/the/a) Cardrooms not card rooms Cases - legal cases should appear in italics, with a v for versus. Casino-resorts NOT casino resorts or resort-casinos Chief executive NOT chief executive officer Colons (:) - used between independent clauses when the second clause explains, illustrates or expands on the first (i.e. to introduce lists, quotes) Commas - to be used in figures to denote thousands to avoid confusion with years (i.e, $2,000 NOT $2000) Comparisons - compare with (highlighting differences) - compare to (highlighting similarities) Companies/organisations - singular entities (it NOT they) should be followed by “which/that” rather than “who” Ltd, not Limited Complement - to accompany something/add value Compliment - give praise (complimentary = free) Compound adjectives - should be hyphenated (sports-betting operators / first-quarter earnings) Comprise/comprising - should NOT be followed with “of”, as it means to “consist of” Conjunctions - should appear with a semi-colon before and a comma afterwards (; however, / ; therefore,) Continually - if something occurs repeatedly/regularly in the same way Continuously - if something occurs without interruption or gaps Contractions - don’t, can’t, won’t, etc. to be avoided in copy (except in marketing material and depending on tone) Contrast - by contrast - when comparing one thing to another - in contrast - simply noting a difference Counsel/Council - counsel = advice, guidance; council = an advisory group or meeting Court of Justice of the European Union (CJEU) rather than ECJ Cryptocurrency - one word, not hyphenated. Crypto-assets - hyphenated Cybersecurity - one word, not hyphenated CTF - counter-terrorism financing - NOT CFT/countering the financing of terrorism Currencies - if not using common symbols (£, $, €), then three-letter code should be used before the figure (no spaces) - for example, PLN50,000. Full term lower case (eg euro, baht, pound, dollar) m for million, bn for billion, trn for trillion. D Date format - Month, Day, Year (e.g., March 7, 2019) For Insights & Analysis summary text: can just say “today”, e.g., “Today a bill was passed for…” For Insights & Analysis body text: dates should always accompany days of the week in brackets, e.g., “On Wednesday (June 8) a bill was passed...” For NIBs: always use dates rather than days. Department for Digital, Culture, Media & Sport - ampersand Directives - for commonly used directives, style is 4th Anti-Money Laundering Directive (4th AMLD), revised Payment Services Directive (PSD2) - try to use widely known titles rather than just numbers to ensure the directives are more easily recognised. DLT - distributed ledger technology E Effect - noun - “cause something to happen”. Em dash (—) - should be used as a conjunction, not a hyphen or en dash (–). Ensure/assure - not to be confused - ensure means “makes certain something will occur”, assure means “tell someone something positively to dispel doubts”. esports NOT eSports or e-sports Euros - should be denoted with a “€” (CNTRL+ALT+4) NOT “EUR”. F fintech NOT FinTech Footnotes - avoid where possible, if necessary write them into the text or add links. G GGR - “gross gaming revenues” Government - does not need a capital g. Governor - should be written out in full, NOT Gov. Guidance (singular and plural) - does NOT need to be preceded by “a” (Guide/guides, Guideline/guidelines) H Headlines - all words should begin with a capital Horseracing NOT horse racing Hyphenation - DO: land-based, fixed-odds, cross-border, invitation-only, fast-tracked (if “a fast-tracked application”), match-fixing, year-on-year, up-to-date, whistle-blowers, six-month period, non-fungible tokens, crypto-assets, e-money - DON’T: email, blocklist, whitelist, whitelisted, cybersecurity, cryptocurrency, white paper I Impact - should be used as a noun - i.e. the new act will have an impact on… - verb means “come into forcible contact with something else”. - using “affect” as a verb is more accurate. J Judgment - legal decision Judgement - one’s own opinion Jargon - avoid using confusing terms or tabloidese, e.g. use players rather than punters. Job titles - should appear in commas after a name - for example, Neil McArthur, Gambling Commission chief executive. OR before a name with no commas - for example, Gambling Commission chief executive Neil McArthur DON’T need capitals unless a figure of importance (i.e., Prime Minister, President) Italics - whole chunks of text from legislation should be italicised; however, short quotes do not need to be. Justice Department - U.S. Department of Justice - to appear with caps (as requested by US team). K KYC - know your customer L Legislature - does not need a capital l. Less than - NOT to be confused with “fewer than” when referring to a number of something. i.e. fewer than 100 gambling tables. Licence - noun (UK), i.e. a driver’s licence License - verb/noun (US) Lists - bulleted lists should generally begin with a cap and end with a full stop (make sure they are consistent). M MONEYVAL NOT Moneyval More than - to be used instead of “over”. i.e., more than 20 players rather than over 20 players. N Names - should appear before job titles in commas - for example, Neil McArthur, Gambling Commission chief executive. Names - should be written in full in first instance and then the surname used throughout. Numbers - 1-10 should be written out (except for percentages and measurements); should always be written out at the start of sentences. Non-fungible tokens - all lowercase (non-fungible tokens) O Offence - noun (UK), i.e. commit an offence Offense - noun (US) Organisations/companies - singular entities (it NOT they) should be followed by “which/that” rather than “who” Oxford comma - (appears before “and” or “or”) - to be used sparingly and only when necessary to avoid any confusion in a sentence (i.e., where more than one “and/or” appears). Over - should not be used as a replacement for “more than”. P Parliament - does not need a capital p. Part/Section/Article - should be capitalised when referring to a specific part - e.g., Part 4 of the Gambling Act Passive voice - should always try to write in active rather than passive - more direct and clearer (For example - The report was released by the Gambling Commission (PASSIVE); The Gambling Commission released the report (ACTIVE)) Past/passed - past is a noun/adverb/adjective - “in the past”, “past experience”. - passed is the past tense of “to pass” - “the law was passed in government”. Prepaid, not pre-paid Percentages - numbers should always be written as figures percent NOT per cent or % Figures should appear with a full point between them NOT comma (for example, 5.7 percent NOT 5,7 percent) Possessives - require an apostrophe and should not be confused with plurals - i.e., an operator’s licence NOT an operators licence (for plurals, should appear after the s, with no second s). Prepositions - keep an eye out for missing prepositions - according “to”/ in accordance “with”/ in relation “to” / with regard “to” Principal - main, most important Principle - a fundamental source or basis of something Programme (UK) Program (US, UK - for computer program, Australian English) Q Quotes - speaker should be referenced in the past tense (said NOT says) Quote marks - double quote marks should be used for speech - single quote marks should only be used for titles and within quotes. (See Quote reference sheet for more information on how to use quotes.) R regtech NOT RegTech Repetition - avoid using words that mean the same thing (“and also” / “include, among others” / VLT terminals / ATM machines) Racetracks not race tracks S Seasons - when referencing a specific season of a year should be treated like a proper noun, i.e. should include a capital - Winter 2018. Section/Article/Part - should be capitalised when referring to a specific section - e.g., Section 4 of the Gambling Act. Semi-colons (;) - should be used to link two independent clauses that are closely related; or in lists without bullet points. (Do not overuse - often a full stop and new sentence will be better.) Sports betting NOT sportsbetting Sports team names Storey (pl. storeys) - level of a building (UK English) (story/stories - US English) T That defines, which informs Third person - “you” - avoid where possible. Titles - all important words should begin with a capital (i.e. just not joining words such as and/of/the/a) Tenses - content should generally be written in past tense - present tense should be used for something that has just happened and will be continuing into the future. U United States abbreviated to U.S. (Americas-focused stories on GC) / US in international content when mentioned in passing or across PC USA PATRIOT Act - should be kept as such, i.e. with caps, as it’s an acronym for “Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act”) U.S. Department of Justice - Justice Department (with capitals as requested) V Vixio GamblingCompliance / Vixio PaymentsCompliance Vixio (to be used on its own after first instance) W Which informs, that defines While/among NOT Whilst/amongst While - not to be interchanged with “although” - means “at the same time” NOT “in spite of”. X Y Year quarters - Q1, Q2, H1, H2, etc. Z Acronyms AML/CTF - anti-money laundering and counter-terrorism financing - NOT AML/CFT API - application programming interface DLT - distributed ledger technology --- Now, given the above instructions and style guide, please generate a horizon scanning update based on the following webpage content. Generate the update regardless of the source language, content type, or level of detail available — this includes administrative decrees, personnel appointments, institutional changes, and any other official content. Use whatever information is present. EBA/RTS/2026/04 19/03/2026 Final report Draft Regulatory Technical Standards amending Commission Delegated Regulation (EU) No 241/2014 on the timing for the application for prior permission to reduce own funds and eligible liabilities instruments under Articles 77, 78 and 78a of Regulation (EU) No 575/2013 FINAL REPORT ON DRAFT REGULATORY TECHNICAL STANDARDS AMENDING COMMISSION DELEGATED REGULATION (EU) NO 241/2014 ON THE TIMING FOR THE APPLICATION FOR PRIOR PERMISSION TO REDUCE OWN FUNDS AND ELIGIBLE LIABILITIES INSTRUMENTS UNDER ARTICLES 77, 78 AND 78A OF REGULATION (EU) NO 575/2013 Contents 1.Executive Summary 3 2.Background and rationale 4 3.Draft regulatory technical standards 6 4.Accompanying documents 11 4.1Draft cost-benefit analysis 11 4.2Feedback on the public consultation 13 2 FINAL REPORT ON DRAFT REGULATORY TECHNICAL STANDARDS AMENDING COMMISSION DELEGATED REGULATION (EU) NO 241/2014 ON THE TIMING FOR THE APPLICATION FOR PRIOR PERMISSION TO REDUCE OWN FUNDS AND ELIGIBLE LIABILITIES INSTRUMENTS UNDER ARTICLES 77, 78 AND 78A OF REGULATION (EU) NO 575/2013 1. Executive Summary Regulation (EU) No 575/2013 of the European Parliament and of the Council of 26 June 2013 on prudential requirements for credit institutions and investment firms and amending Regulation (EU) No 648/2012 had mandated the EBA to develop draft regulatory technical standards (‘RTS’) that, inter alia, updated the procedure for granting the permission to reduce own funds and extended it to eligible liabilities, including the time limits and information requirements and the process of co- operation between competent and resolution authorities. This mandate was fulfilled by means of the EBA/RTS/2021/051 subsequently adopted by the European Commission with Commission Del- egated Regulation (EU) 2023/8272 (‘RTS on own funds and eligible liabilities’). When publishing its final draft RTS on own funds and eligible liabilities on 26 May 2021, the EBA acknowledged comments received during the consultation that the extension of the prior permis- sion regime timeline from 3 to 4 months was too long. While at the time of the publication of the RTS the extension was justified by the need to adequately cater for the more complex assessment that competent and resolution authorities were expected to undertake, the EBA committed to monitoring the practical implementation and authorities’ practices. As a result of the monitoring, it is EBA view that the relevant authorities are now able to process the applications within a shorter period. Therefore, and also considering feedback received from institutions since the publication of the RTS, the EBA deems it reasonable and justified to revert to the shortened time frame of three months to process applications to reduce own funds and eligible liabilities instruments. Next steps The draft regulatory technical standards will be submitted to the EU Commission for endorsement following which they will be subject to scrutiny by the European Parliament and the Council before being published in the Official Journal of the European Union. The draft RTS will amend the Com- mission Delegated Regulation (EU) No 241/2014. 1 Draft Regulatory Technical Standards on own funds and eligible liabilities amending Delegated Regulation (EU) No 241/2014 supplementing Regulation (EU) No 575/2013 of the European Parliament and of the Council with regard to regulatory technical standards for Own Funds requirements for institutions 2 Commission Delegated Regulation (EU) 2023/827 of 11 October 2022 laying down regulatory technical standards amending Delegated Regulation (EU) No 241/2014 as regards the prior permission to reduce own funds and the require- ments related to eligible liabilities instruments. 3 FINAL REPORT ON DRAFT REGULATORY TECHNICAL STANDARDS AMENDING COMMISSION DEL- EGATED REGULATION (EU) NO 241/2014 ON THE TIMING FOR THE APPLICATION FOR PRIOR PER- MISSION TO REDUCE OWN FUNDS AND ELIGIBLE LIABILITIES INSTRUMENTS UNDER ARTICLES 77, 78 AND 78A OF REGULATION (EU) NO 575/2013 2. Background and rationale 1. Regulation (EU) 575/2013 of the European Parliament and of the Council (CRR1) subjected the reduction of own funds to prior permission of the competent authorities and introduced a man- date for the EBA to develop RTS to specify, among other aspects, the procedure for granting this permission. As a result, Delegated Regulation (EU) 241/2014 set out a detailed and comprehen- sive process for competent authorities to grant a supervisory permission for reducing own funds. When defining the timing of the application to be submitted and its processing, Article 31(1) RTS set a timeframe of three month in advance of the date when one of the actions listed in Article 77 CRR are announced to the holders for institutions to transmit the application of the prior permission. 2. Regulation (EU) 2019/876 of the European Parliament and of the Council (CRR2) extended to eligible liabilities the obligation for institutions to obtain permission from the resolution author- ity before calling, redeeming, repaying or repurchasing eligible liabilities instruments and set out the conditions under which the resolution authority must grant the permission. Moreover, CRR2 introduced significant amendments related to the prior permission regime to reduce own funds, in particular, the notion of ‘general prior permission’. Further amendments to the provisions were introduced with a view to codifying existing practices applied by competent authorities. These and other updates in the area of own funds and eligible liabilities were reflected in the Commission Delegated Regulation (EU) 2023/827 amending Delegated Regulation (EU) No 241/2014 that laid down Regulatory Technical Standards developed by the EBA3. 3. The new RTS extended from three to four months the deadline for the application to be submit- ted to the competent and resolution authorities for ad hoc and general prior permission before the date on which any of the actions referred to in Article 77 of Regulation (EU) No 575/2013 would be taken. During the consultation phase, respondents considered the four-month time- line too long. 4. However, the four-month period seemed necessary to cater for the more complex assessment that the competent and resolution authorities needed to undertake in order to verify not only that the institution’s own funds exceeded the respective requirements by the necessary margin but also that the institution’s eligible liabilities met this condition. In addition, the increase in the minimum timeline for the application of the prior permission seemed appropriate at that time to allow resolution authorities sufficient time for interaction with the relevant competent authority as prescribed by Article 78a(3)(a) CRR. The same timing (four months) was set for the application for the general prior permission. Nonetheless, the RTS set the timing of the applica- 3 EBA/RTS/2021/05 4 FINAL REPORT ON DRAFT REGULATORY TECHNICAL STANDARDS AMENDING COMMISSION DEL- EGATED REGULATION (EU) NO 241/2014 ON THE TIMING FOR THE APPLICATION FOR PRIOR PER- MISSION TO REDUCE OWN FUNDS AND ELIGIBLE LIABILITIES INSTRUMENTS UNDER ARTICLES 77, 78 AND 78A OF REGULATION (EU) NO 575/2013 tion for a renewal of general prior permission at three months before the expiration of the ex- isting permission and recognised the possibility of competent and resolution authorities pro- cessing the applications within a shorter time frame. 5. Moreover, the EBA committed to monitoring how the four and three-month time periods for the submission and assessment of applications would be implemented in practice, with a par- ticular focus on how competent authorities and resolution authorities would operationalise their respective assessments as well as their cooperation and consultation. It is considered that authorities have gained the necessary experience and are now able to process ad hoc and gen- eral prior permissions within a period shorter than four months. Reverting to a shorter period will give more flexibility to institutions in their requests for permission for redemption and cap- ital planning purposes while it is still seen as a sufficient and prudent timeline from a supervisory perspective. This would also be in line with repeated comments received from stakeholders on the four-month period since the implementation of the RTS. Therefore, it is proposed to further amend the Commission Delegated Regulation (EU) No 241/2014 with regard to the timeline for the submission of applications for ad hoc and general prior permissions for reductions in own funds and eligible liabilities instruments. 6. The new RTS also set simplified requirements for institutions for which the resolution authority has set an MREL at a level that does not exceed the loss absorption amount. However, Directive (EU) 2024/1174 of the European Parliament and of the Council of 11 April 2024 amending Di- rective 2014/59/EU and Regulation (EU) No 806/2014 as regards certain aspects of the minimum requirement for own funds and eligible liabilities rendered this simplified procedure void by ex- cluding liquidation entities, for which the resolution authority has not determined the require- ment referred to in article 45(1) of that Directive, from the requirement to obtain the prior per- mission of the resolution authority to effect the call, redemption, repayment or repurchase of liabilities that would meet the eligibility requirements for the MREL. Therefore, the references to this simplified requirement for liquidation entities, with an MREL set at the loss absorption amount, are proposed to be deleted from the Commission Delegated Regulation (EU) No 241/2014. This is in line with the proportionate approach for such entities described in the EBA Opinion on the European Commission’s amendments relating to the final draft RTS for own funds and eligible liabilities published on 7 April 2022. For reasons of proportionality and legal certainty, the proposed amendments have been limited to cases where changes to L1 have di- rectly impacted the RTS. While amendments to other L1 provisions might necessitate a compre- hensive review of the RTS, a proportional and efficient approach has been maintained. 5 FINAL REPORT ON DRAFT REGULATORY TECHNICAL STANDARDS AMENDING COMMISSION DEL- EGATED REGULATION (EU) NO 241/2014 ON THE TIMING FOR THE APPLICATION FOR PRIOR PER- MISSION TO REDUCE OWN FUNDS AND ELIGIBLE LIABILITIES INSTRUMENTS UNDER ARTICLES 77, 78 AND 78A OF REGULATION (EU) NO 575/2013 3. Draft regulatory technical standards COMMISSION DELEGATED REGULATION (EU) …/… of XXX amending Delegated Regulation (EU) No 241/2014 supplementing Regu- lation (EU) No 575/2013 of the European Parliament and of the Council with regard to regulatory technical standards for own funds require- ments for institutions (Text with EEA relevance) THE EUROPEAN COMMISSION, Having regard to the Treaty on the Functioning of the European Union, Having regard to Regulation (EU) No 575/2013 of the European Parliament and of the Council of 26 June 2013 on prudential requirements for credit institutions and investment firms and amending Regulation (EU) No 648/20124, and in particular, Article 78(5) third subparagraph and Article 78a(3) fourth subparagraph; Whereas: (1) Commission Delegated Regulation (EU) 2023/8275 extended the application period for the prior permission to reduce own funds referred to in Article 78(1) of Regula- tion No (EU) 575/2013 from three to four months in order to allow sufficient time for the interaction of the resolution authority with the relevant competent authority. The same application period was set for the reduction of the eligible liabilities re- ferred to in Article 78a(1) of that Regulation as well as for new general prior permis- sions to reduce own funds and eligible liabilities referred to in Articles 78(1) second subparagraph and 78a(1) second subparagraph of the said Regulation. Nonetheless, the timing of the application for a renewal of a general prior permission was set at three months. 4 OJ L 176, 27.6.2013, p. 1. 5 Commission Delegated Regulation (EU) 2023/827 of 11 October 2022 laying down regulatory technical standards amending Delegated Regulation (EU) No 241/2014 as regards the prior permission to reduce own funds and the require- ments related to eligible liabilities instruments (OJ L 104, 19.4.2023, p. 1–22) 6 FINAL REPORT ON DRAFT REGULATORY TECHNICAL STANDARDS AMENDING COMMISSION DEL- EGATED REGULATION (EU) NO 241/2014 ON THE TIMING FOR THE APPLICATION FOR PRIOR PER- MISSION TO REDUCE OWN FUNDS AND ELIGIBLE LIABILITIES INSTRUMENTS UNDER ARTICLES 77, 78 AND 78A OF REGULATION (EU) NO 575/2013 (2) After the entry into force of the Commission Delegated Regulation (EU) 2023/827 and considering the experience gained by the relevant authorities during the first years of practical implementation, it was observed that competent and resolution au- thorities are now in a position to process the applications in a shorter period. Accord- ingly, the application period for the reduction of own funds and eligible liabilities, including general prior permissions, should be shortened to three months. (3) To ensure that resolution authorities have sufficient time to assess the applications for the reduction of eligible liabilities instruments under Article 78a(1) of Regulation No (EU) 575/2013 and to consult with the competent authorities within a three- month period, the period of consultation between the competent and the resolution authority should be reduced to a maximum of two months. Accordingly, the period for the resolution authority to communicate to the competent authority its proposed margin by which it considers necessary that the own funds and eligible liabilities of the institution must exceed its requirements should not exceed one month. (4) Following the adoption of Directive (EU) 2024/1174 of the European Parliament and of the Council of 11 April 2024 amending Directive 2014/59/EU and Regulation (EU) No 806/2014 as regards certain aspects of the minimum requirement for own funds and eligible liabilities, liquidation entities for which the resolution authority has not determined the requirement referred to in article 45 of Directive 2014/59/EU no longer require the prior permission of the resolution authority to effect the call, redemption, repayment or repurchase of liabilities that would meet the eligibility criteria for liabilities that may be used to comply with the MREL. Therefore, the provisions in Commission Delegated Regulation (EU) 2023/827 setting a simplified procedure for the prior permission to reduce eligible liabilities for institutions for which the resolution authority has set the minimum requirement for own funds and eligible liabilities laid down in Article 45(1) of Directive 2014/59/EU at a level that does not exceed an amount sufficient to absorb losses becomes obsolete. Delegated Regulation (EU) No 241/2014 should therefore be amended accordingly. (5) This Regulation is based on the draft regulatory technical standards submitted to the Commission by the European Banking Authority. (6) The European Banking Authority has conducted open public consultations on the draft regulatory technical standards on which this Regulation is based, analysed the potential related costs and benefits and requested the advice of the Banking Stake- holder Group established in accordance with Article 37 of Regulation (EU) No 1093/2010 of the European Parliament and of the Council6. 6 Regulation (EU) No 1093/2010 of the European Parliament and of the Council of 24 November 2010 establishing a European Supervisory Authority (European Banking Authority), amending Decision No 716/2009/EC and repealing Com- mission Decision 2009/78/EC (OJ L 173, 12.6.2014, p. 190). 7 FINAL REPORT ON DRAFT REGULATORY TECHNICAL STANDARDS AMENDING COMMISSION DEL- EGATED REGULATION (EU) NO 241/2014 ON THE TIMING FOR THE APPLICATION FOR PRIOR PER- MISSION TO REDUCE OWN FUNDS AND ELIGIBLE LIABILITIES INSTRUMENTS UNDER ARTICLES 77, 78 AND 78A OF REGULATION (EU) NO 575/2013 HAS ADOPTED THIS REGULATION: Article 1 Delegated Regulation (EU) No 241/2014 is amended as follows: (1) Article 31 is amended as follows: (a) paragraph 1 is replaced by the following: ‘1.For a prior permission, other than a general prior permission as referred to in Article 78(1), second subparagraph, of Regulation (EU) No 575/2013, the institution shall transmit a complete application and the information referred to in Article 30 to the competent authority at least three months before the date on which one of the actions listed in Article 77(1) of Regulation (EU) No 575/2013 will be announced to the holders of the instruments.’; (b) paragraph 2 is replaced by the following: ‘2. For a general prior permission as referred to in Article 78(1), second subparagraph, of Regulation (EU) No 575/2013, the institution shall transmit a complete application and the information referred to in Articles 30 and 30a to the competent authority at least three months before the date on which any of the actions listed in Article 77(1) of Regulation (EU) No 575/2013 will be carried out.’; (c) paragraph 3 is replaced by the following: ‘ 3. Where a renewal of a general prior permission pursuant to Article 78(1), second subparagraph, of Regulation (EU) No 575/2013 and Article 30b is sought, the institution shall transmit the application and the information required under Articles 30, 30a and 30b to the competent authority at least three months before the expiration of the period for which the original general prior permission was granted.’ (2) Article 32g is amended as follows: (a) paragraph 1 is replaced by the following: ‘1.For a prior permission, other than the general prior permission referred to in Article 78a(1), second subparagraph, of Regulation (EU) No 575/2013, the institution shall transmit a complete application and the information referred to in Article 32d to the resolution authority at least three months before the date on which one of the actions listed in Article 77(2) of Regulation (EU) No 575/2013 will be announced to the holders of the instruments.’; (b) paragraph 2 is replaced by the following: ‘2. For the general prior permission referred to in Article 78a(1), second subparagraph, of Regulation (EU) No 575/2013, the institution shall transmit a complete application and the information referred to in Articles 32d and 32e to the resolution authority at least three months before the date on which one of the actions listed in Article 77(2) of Regulation (EU) No 575/2013 will be carried out.’; (c) paragraph 3 is replaced by the following: 8 FINAL REPORT ON DRAFT REGULATORY TECHNICAL STANDARDS AMENDING COMMISSION DEL- EGATED REGULATION (EU) NO 241/2014 ON THE TIMING FOR THE APPLICATION FOR PRIOR PER- MISSION TO REDUCE OWN FUNDS AND ELIGIBLE LIABILITIES INSTRUMENTS UNDER ARTICLES 77, 78 AND 78A OF REGULATION (EU) NO 575/2013 ‘3. Where a renewal of the general prior permission pursuant to Article 78a(1), second subparagraph, of Regulation (EU) No 575/2013 and Article 32f is sought, the institution shall transmit a complete application and the information required under Articles 32d, 32e and 32f to the resolution authority at least three months before the expiration of the period for which the original general prior permission was granted.’ (3) Article 32h is deleted; (4) Article 32i is amended as follows: (a) paragraph 1 is replaced by the following: ‘1. Where a complete application for a prior permission, including the general prior permis- sion referred to in Article 78a(1), second subparagraph, of Regulation (EU) No 575/2013, is submitted by an institution, the resolution authority shall promptly transmit that application to the competent authority, including the information referred to in Article 32d and, where applicable, Article 32e or Article 32f.’ (b) paragraph 3 is replaced by the following: ‘3.The competent authority and the resolution authority shall agree on an adequate time limit for providing a response to the consultation referred to in paragraph 2, which shall not exceed two months from the moment of receipt of the request for consultation, including where the consultation concerns the renewal of a general prior permission pursuant to Article 32f. The resolution authority shall consider the views received from the competent authority before taking a decision on the permission.’ (c) paragraph 4 is replaced by the following: ‘4. Where the agreement of the competent authority is required in accordance with Arti- cle 78a(1), point (b), of Regulation (EU) No 575/2013, the resolution authority shall com- municate to the competent authority, within one month from the request for consultation referred to in paragraph 2, including where the consultation concerns the renewal of a gen- eral prior permission pursuant to Article 32f, the proposed margin by which, following the action referred to in Article 77(2) of that Regulation, the resolution authority considers nec- essary that the own funds and eligible liabilities of the institution must exceed its require- ments.’ (d) paragraph 5 is replaced by the following: ‘5. Within three weeks or, where the consultation concerns the renewal of a general prior permission pursuant to Article 32f, within two weeks, after receiving the communication referred to in paragraph 4, the competent authority shall transmit its written agreement to the resolution authority. In the event that the competent authority disagrees or partially disagrees with the resolution authority, it shall inform the resolution authority within that period, stat- ing its reasons.’ (e) paragraph 7 is replaced by the following: ‘7. By way of derogation from paragraphs 3 to 6, where the maximum time period for processing the application referred to in paragraph 1 is shorter than three months in accordance with Article 32g, paragraph 4, the periods of time referred to in paragraphs 3, 4 9 FINAL REPORT ON DRAFT REGULATORY TECHNICAL STANDARDS AMENDING COMMISSION DEL- EGATED REGULATION (EU) NO 241/2014 ON THE TIMING FOR THE APPLICATION FOR PRIOR PER- MISSION TO REDUCE OWN FUNDS AND ELIGIBLE LIABILITIES INSTRUMENTS UNDER ARTICLES 77, 78 AND 78A OF REGULATION (EU) NO 575/2013 and 5 shall be agreed between the resolution authority and the competent authority taking into account the relevant maximum time period.’ Article 2 This Regulation shall enter into force on the twentieth day following that of its publication in the Official Journal of the European Union. This Regulation shall be binding in its entirety and directly applicable in all Member States. Done at Brussels, For the Commission The President 10 FINAL REPORT ON DRAFT REGULATORY TECHNICAL STANDARDS AMENDING COMMISSION DEL- EGATED REGULATION (EU) NO 241/2014 ON THE TIMING FOR THE APPLICATION FOR PRIOR PER- MISSION TO REDUCE OWN FUNDS AND ELIGIBLE LIABILITIES INSTRUMENTS UNDER ARTICLES 77, 78 AND 78A OF REGULATION (EU) NO 575/2013 4. Accompanying documents 4.1 Draft cost-benefit analysis As per Article 10(1) of the EBA Regulation (Regulation (EU) No 1093/2010 of the European Parlia- ment and of the Council), any RTS developed by the EBA shall be accompanied by an Impact As- sessment (IA) annex which analyses ‘the potential related costs and benefits’ before submitting to the European Commission. The analysis below provides the reader with an overview of the problem identification, the options identified to remove the problem and their potential impacts. This analysis is commensurate to the limited and target amendments of the RTS, and is kept at high- level and is qualitative in nature. A. Problem identification The latest update of the RTS extended the timeline for the submission of applications of ad hoc permissions and new general prior permissions from three to four months. During the consultation phase, respondents considered the four-month timeline too long. The EBA committed to monitoring the implementation of these provisions, with a particular focus on how competent authorities and resolution authorities would operationalise their respective as- sessments as well as their cooperation and consultation. It was concluded in 2024 that authorities were able to process ad hoc and new general prior permissions within a period shorter than four months. B. Policy objectives The main objective of this RTS is to shorten the minimum time frame for institutions to submit their applications for ad-hoc and new general prior permissions to reduce own funds and eligible liabili- ties. This will give institutions more flexibility in their requests for permission for redemption and capital planning purposes while maintaining a sufficient and prudent timeline from a supervisory perspective. This reduction will be in line with repeated comments received by stakeholders on the length of the period. C. Baseline scenario In the absence of the proposed changes, competent and resolution authorities may allow institu- tions to submit the application within a time frame shorter than four months only on a case-by- case basis and under exceptional circumstances, as stated in Articles 31(4) and 32g(4) of Delegated Regulation 241/2014. 11 FINAL REPORT ON DRAFT REGULATORY TECHNICAL STANDARDS AMENDING COMMISSION DEL- EGATED REGULATION (EU) NO 241/2014 ON THE TIMING FOR THE APPLICATION FOR PRIOR PER- MISSION TO REDUCE OWN FUNDS AND ELIGIBLE LIABILITIES INSTRUMENTS UNDER ARTICLES 77, 78 AND 78A OF REGULATION (EU) NO 575/2013 D. Options considered In order to ensure a harmonised and consistent approach in the Union concerning the time frame for institutions to submit their applications for ad-hoc and new general prior permissions to reduce own funds and eligible liabilities, the amendment of the RTS was considered as the sole option. Maintaining the current drafting of the RTS could not be considered as an available option, because even though Articles 31(4) and 32g(4) allow competent authorities to permit institutions ‘on a case- by-case basis and under exceptional circumstances’ to transmit their prior permission applications within a time frame shorter than four months, those Articles would not allow for the transmission of the prior permissions on a systematic basis and the adherence to the convergent and compre- hensive process described in the RTS. E. Cost-Benefit Analysis The respondents to the public consultation of the latest update of the RTS will welcome this change, as the proposed amendments would be in line with repeated comments received from stakehold- ers on the lengthy four-month period applicable since the implementation of the revised RTS. In addition, the results of the monitoring work carried out by the EBA have shown that competent and resolution authorities, after several years of practical implementation of the RTS provisions, are now in a position to process the applications received in a three-month timeframe. It is there- fore expected that they can implement these amendments to the RTS smoothly and without addi- tional burden and cost. Finally, the proposed amendments follow the steps of the mandate under Articles 78(5) and 78a(3) CRR, without altering the objectives. 12 FINAL REPORT ON DRAFT REGULATORY TECHNICAL STANDARDS AMENDING COMMISSION DEL- EGATED REGULATION (EU) NO 241/2014 ON THE TIMING FOR THE APPLICATION FOR PRIOR PER- MISSION TO REDUCE OWN FUNDS AND ELIGIBLE LIABILITIES INSTRUMENTS UNDER ARTICLES 77, 78 AND 78A OF REGULATION (EU) NO 575/2013 4.2 Feedback on the public consultation The EBA has publicly consulted on the draft proposal for these technical standards. The consultation period lasted for three months and ended on 9 October 2025. Three responses were received, two of which were published on the EBA website. Summary of key issues and the EBA response All respondents agreed with the proposed amendment to the RTS and welcomed the reduced timeframe to process the application to reduce own funds and eligible liabilities instruments. The submitters’ responses to the specific question of the consultation and general comments, to- gether with the EBA analysis and the actions taken to address them, if deemed necessary, are in- cluded in the feedback table. 13 FINAL REPORT ON DRAFT REGULATORY TECHNICAL STANDARDS AMENDING COMMISSION DELEGATED REGULATION (EU) NO 241/2014 ON THE TIMING FOR THE APPLI- CATION FOR PRIOR PERMISSION TO REDUCE OWN FUNDS AND ELIGIBLE LIABILITIES INSTRUMENTS UNDER ARTICLES 77, 78 AND 78A OF REGULATION (EU) NO 575/2013 Summary of responses to the consultation and the EBA’s analysis Comments Summary of responses received EBA analysis Amendments to the proposals General comments Removing the need for prior Two respondents suggested that the reduction The proposed amendments of the RTS are of a n/a permission to reduce MREL if of eligible liabilities/MREL should not be sub- targeted nature in order to reap the immediate certain conditions are met ject to a prior permission when, as a result of simplification benefits derived from the reduc- the reduction, the institution’s own fund and tion of the prior permission deadline. MREL continue to be above the prudential re- All liabilities qualifying as eligible liabilities in- quirements or the institution does not start de- struments fall under the permission regime of pleting its capital buffers. Articles 77(2) and 78a CRR. Therefore, this pro- posal would entail a review of the Level 1 text. Introduction of proportional- A respondent suggested the introduction of a The proposed amendments of the RTS are of a n/a ity for transactions with lim- simpler prior permission process where the targeted nature in order to reap the immediate ited impact transaction has limited impact on own funds simplification benefits derived from the reduc- and eligible liabilities. tion of the prior permission deadline. This proposal could be considered in the context of a potential future comprehensive review of the RTS. 14 FINAL REPORT ON DRAFT REGULATORY TECHNICAL STANDARDS AMENDING COMMISSION DELEGATED REGULATION (EU) NO 241/2014 ON THE TIMING FOR THE APPLI- CATION FOR PRIOR PERMISSION TO REDUCE OWN FUNDS AND ELIGIBLE LIABILITIES INSTRUMENTS UNDER ARTICLES 77, 78 AND 78A OF REGULATION (EU) NO 575/2013 Simplified information con- Two respondents noted that the content of the The proposed amendments of the RTS are of a n/a tent for the application to application to be submitted by institutions de- targeted nature in order to reap the immediate reduce own funds and eligi- tailed in Articles 30 and 32d should be simpli- simplification benefits derived from the reduc- ble liabilities fied, as they consider it too burdensome for tion of the prior permission deadline. both competent authorities and institutions, This proposal could be considered in the context redundant with some regular reports, and po- of a potential future comprehensive review of tentially obsolete in some parts. the RTS. Special ad hoc prior permis- Two respondents suggested streamlining the The proposed amendments of the RTS are of a n/a sion for liability management ad hoc permissions to allow a predetermined targeted nature in order to reap the immediate exercises (LMEs) amount applicable to a list of instruments simplification benefits derived from the reduc- whose nominal amount may be higher than the tion of the prior permission deadline. permission envelope. This proposal would entail a deeper review which is out of scope of the RTS. Responses to questions in Consultation Paper EBA/CP/2025/14 Question 1. Do you consider it appropriate to revert to a three-month deadline for the prior permission regime for own funds and eligible liabilities instruments? 15 FINAL REPORT ON DRAFT REGULATORY TECHNICAL STANDARDS AMENDING COMMISSION DELEGATED REGULATION (EU) NO 241/2014 ON THE TIMING FOR THE APPLI- CATION FOR PRIOR PERMISSION TO REDUCE OWN FUNDS AND ELIGIBLE LIABILITIES INSTRUMENTS UNDER ARTICLES 77, 78 AND 78A OF REGULATION (EU) NO 575/2013 All the respondents welcomed the reversion to The proposed reduction of the deadline is the re- n/a a three-month deadline. Nonetheless, two re- sult of the EBA monitoring of competent author- spondents also considered that a further reduc- ities’ practices. The EBA will keep monitoring tion would be more appropriate to allow for these practices and the practical implementation greater flexibility in banks’ capital planning. of the proposed amendment. 16

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