Internal barriers, resolvability and banking union integration - Eurofi article by SRB Chair Dominique Laboureix | Nicosia, March 2026

The establishment of the single rulebook, together with the Single Supervisory Mechanism (SSM) and the Single Resolution Mechanism (SRM), represents a major step forward in European financial integration. These reforms have significantly reduced regulatory fragmentation and enabled banks to operate across borders under a harmonised supervisory and crisismanagement framework, thereby strengthening the foundations of the Single Market for financial services. 

By law, the Single Resolution Board (SRB) is mandated to act in the interest of all participating Member States. In practice, the SRB and national resolution authorities work side by side on a daily basis and take decisions together, both ex ante in resolution planning and, when needed, in a crisis. This collegial and cooperative approach is critical to ensuring a fair, consistent and effective framework and fostering trust among Banking Union Member States. From that perspective, the distinction between Home and Host countries should fade within the Banking Union, as decisions are taken jointly in the service of European financial stability. Only insolvency laws and deposit guarantee schemes still lack sufficient harmonisation, although the recent CMDI package brings improvements. 

Beyond this legal reality, in the last ten years Europe has built strong common supervision and a solid resolution framework. Resolution plans have been developed for all major European lenders, the Single Resolution Fund has reached EUR 80 bn, banks have built substantial loss-absorption buffers and, importantly, resolution in Europe has been shown to work across different Member States.

 Moving toward a progressive removal of internal capital and liquidity barriers within cross-border banking groups should be considered to improve efficiency, competitiveness and private risk-sharing in the EU. Intragroup prepositioning should be reconsidered in a well-integrated Banking Union based on a trusted institutional architecture. 

Given the progress achieved in terms of resilience and common governance, one could expect that “host Member States” concerns would diminish. In practice, however, the home-host issue remains relevant, reflecting residual mistrust and the incomplete nature of the overall framework. 

This shows that, despite progress, the Banking Union remains incomplete — still lacking a European Deposit Insurance Scheme and a common public liquidity backstop. 

One way to achieve further integration and foster trust is to recall that the vast majority of Banking Union groups operate under a Single Point of Entry (SPE) resolution strategy. When the SRM determines that an SPE strategy is appropriate, extensive pre-positioning becomes less relevant for certain banks, as their group can be managed in a crisis as a single entity. As such, some pre-positioning aspects remain relevant, particularly internal MREL, while others driven by supervisory considerations may be less pertinent from a resolution perspective. 

Rethinking pre-positioning for SPE groups would not imply a lowering of standards or come at the expense of resilience. On the contrary, it should provide greater flexibility for banks in going concern while preserving the pool of resources available to deploy across the group and increasing the ability of banks and authorities to direct them where and when needed at the moment of resolution. 

As said, pre-positioning of MREL and liquidity can be useful depending on the structure and business model of each group. In some cases, the SRM determines that a Multiple Point of Entry resolution strategy is appropriate, reflecting a sufficiently decentralised structure that allows for separate and credible resolution of entities. In such cases, a higher degree of pre-positioning is justified. 

This underscores the importance of selecting, together with national authorities, the resolution strategy that best fits each group’s structure and ensuring it can be executed effectively. Bank resolutions are inherently complex and uncertain, but decisions are always taken in the interest of the Banking Union as a whole, as shown in the resolution cases to date. 

Since pre-positioning is mainly intended for crisis situations, the SRM — through close and continuous cooperation between the SRB and national authorities — is well placed to assess whether measures are necessary, proportionate and effective in light of the chosen strategy, and to use the flexibility in the current framework to support further integration. 

However, legislation influenced by the bad memories of the Global Financial Crisis leaves limited room for manoeuvre. Over time, deeper integration will require targeted Level 1 changes. 

Such amendments would acknowledge the progress achieved over the past decade in crisis management and risk reduction, while further integration will depend on strengthening the crisismanagement toolkit, notably through improved liquidity in resolution.