Comments by the German Banking Industry Committee on the ECB’s consultation on O&Ds

On 8 November 2024, the European Central Bank (ECB) initiated a public consultation on revised policies on the options and discretions (O&Ds) available to supervisory authorities under Union law, last revised in 2022. On 10 January 2025, the German Banking Industry Committee submitted its comments on this consultation.

O&Ds allow member states and supervisory authorities to choose between alternative approaches (options) or to apply certain provisions flexibly (discretions). Since 2016, the ECB Banking Supervision Guide and accompanying documents have ensured that the exercise of options and discretions within the Single Supervisory Mechanism (SSM) is standardised. The current revisions take into account changes arising from the EU Banking Package.

A link to GBIC’s positions on the individual subject areas of the guidelines and the accompanying documents can be found below.