EBA Discussion paper on proportionality assessment methodology

The GBIC has submitted comments on the discussion paper on the proportionality assessment methodology developed by the EBA. Its aim is to provide policy experts with evidence on the need for applying proportional treatment of institutions. The GBIC welcomes this approach but believes improvements need to be made to the specific design of the individual classifications.

Downloads

Stellungnahme Verhältnismäßigkeitsprüfung

PDF

19.10.2022

Download

This might also interest you:

Comments

16th of March 2026

GBIC comments on amending Delegated Regulation (EU) 2019/98

The German Banking Industry Committee (GBIC) welcomes the objective of revising Commission Delegated Regulation (EU) 2019/980 to simplify prospectus requirements, streamline their content and further standardise format and structure, thereby reducing administrative burdens for issuers, improving comparability for investors and strengthening access to EU capital markets.

Comments

21st of January 2026

Input on a revised Delegated Act concerning standards for sustainability reporting

under the Corporate Sustainability Reporting Directive (CSRD)

The German Banking Industry Committee (DK) has taken a position on the revision of the ESRS and the EU taxonomy as part of the participation process initiated by the Federal Ministry of Justice and Consumer Protection (BMJV).

Comments

30th of December 2025

GBIC Comments on the Draft Implementing Act for EUDIW User Onboarding under eIDAS 2.0

The statement relates to the European Commission’s draft implementing act on the onboarding of users to the European Digital Identity Wallet (EUDIW) under the amended eIDAS-Regulation (eIDAS 2.0).