On 02 October 2024, the European Banking Authority (EBA) published its Work Programme for 2025, outlining its plan to fulfil its mission and mandates for the upcoming year, based on EU legislation and its founding regulation. The Programme supports broader EU financial sector priorities, organized into five key areas for the next three years: (i) the EU Single Rulebook, (ii) Financial stability, (iii) Data management, (iv) Oversight of DORA and MiCAR and (v) conduct and AML/CFT supervision. 

In more detail, in 2025, EBA will address a wide range of mandates related to the financial sector, with a strong focus on implementing the EU banking package (CRR III/CRD VI) to further develop the EU Single Rulebook. Its ongoing analyses, risk metrics and stress – testing methodologies aim to ensure financial stability and address risks from economic and geopolitical developments. Additionally, the EBA will begin overseeing critical 3rd party IT services under DORA and supervising significant crypto – asset providers under MiCAR. It will also establish a new EU AML – CFT framework. 

 

Introduction

The European Banking Authority (EBA) has set its strategic priorities for 2025 – 2027, focusing on key areas that will shape the future of the EU financial sector. These priorities reflect the EBA’s commitment to regulatory oversight, financial stability, technological advancement and consumer protection. Organised around five key pillars, the EBA’s efforts will address ongoing and emerging challenges in the banking and financial landscape:

  1. Strengthening the EU Banking Framework
  2. Promoting Financial Stability
  3. Advancing Data Management
  4. Overseeing New Digital Regulations
  5. Focusing on Consumer Protection and AML/CFT framework 

 

EBA’s five key Pillars

As part of Pillar 1, which focuses on implementing the EU Banking package and enhancing the Single Rulebook, the EBA will undertake several critical initiatives in 2025. A key priority will be implementing Basel III reforms in the EU to strengthen the regulatory framework with more risk – sensitive approaches to capital requirements. Following the June 2024 finalization of the CRR/CRD package, the EBA will deliver over 140 regulatory standards, guidelines and reports to enhance supervision and risk control in the EU financial sector. The EBA will also ensure that its regulatory products incorporate proportionality, reducing compliance burdens for small and medium – sized banks. In addition, EBA will integrate ESG – related mandates into its activities, focusing on environmental, social and governance exposures and disclosures. EBA will also work with the European Commission on reports regarding the Covered Bond Directive and by 2025, provide advice on non – EU institutions and insolvency benchmarking. Lastly, the EBA will continue to improve the accessibility and user – friendliness of the Single Rulebook, ensuring it remains an effective tool for stakeholders. 

In 2025, under Pillar 2, the EBA will concentrate on enhancing financial stability through a forward – looking, risk – based approach to ensure a sustainable economy. A key focus will be analysing the impact of rising interest rates, high inflation and potential credit crunches on the banking sector, particularly given on the ongoing geopolitical uncertainties and economic instability. Moreover, EBA will strengthen efforts to address challenges related to cyber – resilience in the financial sector, responding to risks posed by the unstable global environment, as well as, expanding its ESG monitoring framework to track environmental, transition and physical risks within the banking industry. In terms of climate – related risks, the EBA will develop a regular climate stress test and related guidelines, building on the 2024 climate scenario analysis to refine its methodologies and incorporate proportionality. Lastly, EBA will update its EU – wide stress test methodology for 2025, with particular emphasis on areas such as Net Free and Commission Income (NFCI), which may require additional resources. 

Furthermore, as part of Pillar 3, the EBA will prioritise enhancing data infrastructure and launching a new data portal to support regulatory objectives. A significant focus will be on providing how regulatory data is acquired, processed and shared, which will enhance the authority’s analytical capabilities. To facilitate this, the EBA will expand the use of EUCLID platform for better data flows and insights and establish a dedicated Pillar 3 hub. EBA will also broaden its reporting framework to include new entities such as DORA and MiCAR, while integrating ESG – related data and metrics into its disclosures and reporting processes. In collaboration with EIOPA, the EBA will finalize its new Data Point Model (DPM) standard 2.0 by 2025, which aims to improve reporting and digital processing. Ultimately, these initiatives will not only streamline reporting processes but also ensure that the EBA remains responsive to the evolving regulatory landscape. 

Under Pillar 4, the EBA will embark on the oversight and supervisory activities related to DORA and MiCAR, emphasizing the regulation of digital operational resilience and crypto – assets. The implementation timeline for DORA is set for January 2025, while MiCAR will begin its application between mid – 2024 and early 2025. To support these efforts, EBA will develop an IT system designed specifically for overseeing DORA. Additionally, the EBA will enhance its supervision of asset – referenced tokens and e – money tokens by 2025 and the process will be guided by the Crypto – Assets Standing Committee ensuring convergence and cooperation among relevant authorities. These initiatives will strengthen the regulatory framework, promoting a secure and efficient digital finance environment. 

Finally, under Pillar 5, the EBA will prioritise the establishment of consumer – oriented mandates while facilitating a smooth transition to the new AML/CFT framework. To this end, EBA will retain its anti – money laundering (AML) and counter – party – terrorist financing (CFT) responsibilities until December 2025, ensuring continuity until the new EU AML authority (AMLA) takes over. The EBA will provide crucial guidance to the European Commission regarding the new AML/CFT framework and foster operational collaboration with AMLA to ensure a cohesive and effective regulatory structure. Protecting consumers and ensuring their access to banking services will be central to the EBA's agenda, particularly in relation to mandates stemming from MiCAR and the Credit Servicers and Credit Purchasers Directive. The EBA will also actively monitor financial innovations, including developments in crypto-assets and AI/ML applications, to identify emerging risks and opportunities, and may publish relevant reports and opinions. Additionally, the authority will track advancements in supervisory (SupTech) and regulatory (RegTech) technologies, contributing insights to legislative proposals concerning digital finance and the digital Euro. Collaboration with ESMA, EIOPA, and the European Commission through the EU Supervisory Digital Finance Academy (SDFA) will enhance supervisory capabilities in digital finance, aligning with the overarching EU Digital Finance Strategy. Lastly, the EBA will begin implementing over 45 mandates from the revised Deposit Guarantee Schemes Directive, PSD3, and the new Payment Service Regulation, with a strong emphasis on preventing payment fraud and safeguarding consumer interests.

 

Conclusion

In conclusion, the European Banking Authority’s Work Programme for 2025 lays out a comprehensive and strategic roadmap to navigate the evolving landscape of the EU financial sector. By focusing on five key pillars, the EBA is dedicated to strengthening regulatory frameworks, enhance financial stability, and promote technological advancements while prioritizing consumer protection. The initiatives outlined in the Programme reflect a commitment to addressing both current and emerging challenges, including the implementation of crucial reform, oversight of digital assets and the establishment of a robust AML/CFT framework. As the EBA embarks on these ambitious objectives, its efforts will not only contribute to a more resilient and secure banking environment but also support sustainable economic growth within the EU. The successful execution of this Work Programme will be vital in fostering trust and confidence in the financial system, ensuring that it remains adaptable and responsive to the needs of all stakeholders in an increasingly complex and interconnected world.