*All figures and documents available in this section reflect the situation as of the day the Decision on the calculation of the 2023 ex-ante contributions (decision SRB/ES/2023/23 of 2 May 2023) was adopted.
Each year, pursuant to Article 70(2) of the Regulation (EU) No 806/2014, the Single Resolution Board determines the annual ex-ante contributions to be raised from institutions within its scope. In this section, please find further information on the 2023 ex-ante contribution cycle and, in particular, on the target level, institutions in scope, the risk adjustment factor, the consultation procedure and the ongoing litigation.
Target level and amount to be collected
- When setting the target level for 2023, the SRB took into account, as it does every year, the requirements as prescribed by the applicable legal framework, i.e. (expected) growth of covered deposits, business cycle, impact on the financial position of institutions, and above all the obligation to reach the final target level at the end of the initial period (31/12/2023) (Article 69 Regulation (EU) No 806/2014).
- As the 2023 cycle is the last of the initial period, the Board determined the 2023 annual target level, by taking into account:
- (i) the expected target level to be reached at the end of the initial period (based on the projected growth of covered deposits in 2023) as well as
- (ii) the available financial means in the Fund at 31 December 2022,
- (iii) the expected economic return of the available financial means in 2023,
- (iv) the settlement of the differences arising as a result of restated data and
- (v) the reimbursement of the remaining share of the 2015 ex-ante contributions.
- As such, the 2023 annual target level is set as the difference between the expected target level on 31 December 2023 and the expected available net financial means in the Fund on 31 December 2023, as below:
Annual target level 2023 = Expected target level 31.12.2023 (eTL) – Expected available net financial means 31.12.2023 (eAFM)
- eTL = (1 + expected % rate of growth of covered deposits 2023) x covered deposits 31.12.2022 x 1%
- eAFM = available financial means 31.12.2022 + restatements 2023 – 2015 deductions 2023 + expected return on the available financial means 2023
- The historical data suggests a constant growth trend during that period in the covered deposits of all credit institutions in the Member States participating in the Banking Union. After the high levels of growth observed in 2020 and in 2021, the growth rate of covered deposits has decelerated in 2022. In particular, according to the data set provided by the Deposit Guarantee Schemes (DGSs) with respect to the previous year, in 2022, the average amount of covered deposits, calculated quarterly, of all credit institutions in the participating Member States amounted to EUR 7,339,364,226,282.55. This figure represents a growth of 2.98% vis-à-vis the yearly average of covered deposits calculated on a quarterly basis reported by the DGSs in 2021.
- The Board concluded that it is reasonable to expect continued firm growth in covered deposit levels in the Banking Union over the last year of the initial period, i.e. a growth rate at 4.5%. This is in line with what has been observed over the course of that initial period from 2016-2022 in terms of average growth and median growth. Based on this expected growth rate, the target level of the Fund at the end of the initial period (31 December 2023) is expected to reach EUR 77,6bn.
- The Board also assessed the phase of the business cycle and the potential pro-cyclical impact that contributions may have on the financial position of contributing institutions. Recent GDP projections have stopped deteriorating and inflation shows signs of slowing down. Furthermore, the euro area institutions' capital and liquidity ratios remain robust and profitability remains strong
- Taking into account all the above factors, the SRB set the total amount of contributions to the SRF for the 2023 ex-ante contribution period (the “annual target level”) EUR 11,702,958,514.31. This represents a decrease of 18% compared to the 2022 ex-ante contributions.
- The total amount of the ex-ante contributions that is expected to be collected by the SRB in June 2023 amounts to EUR 11,28 billion. This amount takes into account the deduction of the 2015 ex-ante contributions and the impact of data restatements and revisions.
The next phases of the 2023 contributions period are the following:
- before 31 May 2023, the 2023 Decision must be notified by National Resolution Authorities as required by Article 20(6) of Commission Delegated Regulation (EU) 2015/63;
- 28 June 2023: the NRAs transfer the contributions to the SRB
Institutions in scope
- In 2023, 2 777 institutions are in the scope of the SRF (down slightly from 2 896 in 2022). The decrease in the number of institutions is mainly due to further market consolidation and/or loss of banking license.
- The institutions in scope of the SRF could be split further in the following three categories:
- 40% are small institutions eligible for a lump sum contribution under Article 10 and mortgage institutions under Article 11 of the Commission Delegated Regulation (EU) 2015/63;
- 29% are risk-adjusted institutions (that pay 94% of the total amount to be collected) under Article 5-9 Commission Delegated Regulation (EU) 2015/63; and
- 31% are medium-size institutions (institutions whose total assets are equal to, or less than, EUR 3 000 000 000 and that do not qualify for the treatment under Article 10 of Commission Delegated Regulation (EU) 2015/63) that are in scope based on Article 8(5) of Council Implementing Regulation (EU) 2015/81. Their contributions consist of (i) a lump sum of EUR 50 000 (for the first EUR 300 000 000 of total liabilities, less own funds and covered deposits) plus (ii) a risk-adjusted contribution (for the total liabilities less own funds and covered deposits above EUR 300 000 000) determined in accordance with Articles 4 to 9 of Commission Delegated Regulation (EU) 2015/63.
- The distribution of the burden for payment of the 2023 ex-ante contributions did not change significantly compared to previous ex-ante contribution cycles. The 20 largest contributors at group level represent 70% of the total 2023 ex-ante contributions, (68% in 2022).
Risk adjustment factor in the euro area
|Intervals for the risk adjustment factor||SRM risk adjustment factors:
number of banks in each interval
With regard to the 2023 contribution period, the table above shows the distribution of the risk adjustment factors, computed and rescaled over the range between 0.8 and 1.5 in accordance with Article 9(3) of Commission Delegated Regulation (EU) 2015/63:
- 11% of the risk-adjusted entities (176 institutions) are classified with a risk adjustment factor between 0.8 and 1;
- the risk adjustment factor for 78% of the risk-adjusted entities (1 294 institutions) ranges from 1 to 1.3;
- 11% of the risk-adjusted entities (182 institutions) are classified with a risk adjustment factor ranging from 1.3 to 1.5.
- In 2023, the SRB provided institutions with the possibility to comment on the main elements of the ex-ante calculation decision. The consultation procedure, which was firstly introduced during the 2021 cycle, further enhances transparency in light of the principle of good administration and with a view to upholding an effective dialogue. A dedicated consultation platform was made available to institutions to facilitate the review of the documents consulted on and the submission of comments.
- Institutions were able to provide their comments through a consultation process between 23 March and 5 April 2023 and to this end were provided with: i) a preliminary draft of the main body of the decision on calculation of contributions for the 2023 cycle; ii) preliminary calculation results. Common data-points and the provision of bin thresholds provided visibility on the binning process and allowed for the accurate estimation by the institutions of their individual contributions while respecting confidentiality requirements.
- A total of 42 institutions (61 in 2022) participated by providing a total of 235 comments. The most commented topics were Target Level and Calculation Methodology, followed by Procedure and Calculation Results. The majority of comments was received in English, the next language used for submissions was German. All the comments received where carefully considered by the SRB and were comprehensively addressed in the 2023 ex-ante calculation decision, in particular Annex III.
Launching the 2023 ex-ante contributions cycle
The Single Resolution Board (“SRB”) announced the start of the 2023 ex-ante contributions cycle for the calculation and collection of ex-ante contributions to the Single Resolution Fund (“SRF”).
As always, the first phase of the cycle is the collection of data pertaining to the institutions under the obligation to contribute to the SRF, which is used to determine their 2023 ex-ante contributions. The SRB has provided the 2023 Data Reporting Form and the related documentation to the National Resolution Authorities (“NRAs”), which are in turn distributed the data collection package to the institutions under their remit.
For an overview of the key steps and the preliminary timeline of the 2023 ex-ante contributions cycle, you can consult the 2023 cycle Kick-off letter (link below).