The EBA Consults On Revised Guidelines On Internal Governance

The European Banking Authority (EBA) today launched a consultation on its revised Guidelines on internal governance under the Capital Requirements Directive (CRD). The proposed revisions reflect the changes introduced in the CRD framework as well as in other relevant legislations, such as the Digital Operational Resilience Acts (DORA). The consultation runs until 5 October 2025 and is limited to the proposed changes.

The draft revised Guidelines have been amended to reflect the changes brought by CRD VI. They specify further the requirements under Article 88(3) of CRD VI, to ensure that each member of the management body, senior manager and key function holder have a documented statement of role and duties, and that a mapping of duties of the members of the management body, senior managers and key function holders has been drawn up.  They also provide specific guidance to ensure that third-country branches have a robust governance framework in place.

The draft revised Guidelines have been amended also to ensure alignment with the DORA Regulation and take into account the findings of the EBA benchmarking Report of diversity practices and gender-neutral remuneration policies. Finally, they also consider the lessons learned from supervisory practices across the EU.

Consultation process

Comments to the consultation paper can be sent by clicking on the "send your comments" button on the EBA's consultation page. The deadline for the submission of comments is 5 October 2025.

The EBA will hold a virtual public hearing on 5 September from 11:30 to 13:00 - Paris time. The EBA invites interested stakeholders to register using this link by 1 September (16:00 CEST). The dial-in details will be communicated to those who have registered for the meeting.

All contributions received will be published following the end of the consultation, unless requested otherwise.

Legal basis

The Guidelines on internal governance have been developed in accordance with Article 74(3) of Directive 2013/36/EU, which mandates the EBA to draft guidelines in this area, and in accordance with Article 48g(9) of Directive 2013/36/EU, which mandates the EBA to draft guidelines on internal governance arrangements, processes and mechanisms for third country branches.

The revision of the EBA Guidelines on internal governance is part of EBA’s roadmap on the implementation of the banking package (CRR III / CRDV VI) which came into application on 1st January 2025 and will, together with its set of regulatory products, further underpin a robust regulatory framework, efficient supervision, and enhanced risk control by credit institutions.