FIA has responded to the European Banking Authority consultation on draft guidelines on common procedure and methodologies for the supervisory review and evaluation process (SREP).
FIA highlights issues for consideration by the EBA for the SREP guidelines, with the aim of increasing proportionality and increase alignment with existing EU regulatory frameworks in the Operational Resilience space.
The introduction of Operational Resilience as a broad concept in the SREP Guidelines does not align with the EU regulatory framework. While certain specific elements are included within the EU regulatory framework, such as DORA and the EBA Draft Guidelines on the sound management of third-party risk, these do not fully cover the holistic concept of ‘Operational Resilience’ as expressed in the SREP Guidelines.
The absence of a clear and consistent approach across member states will lead to fragmented and varying implementations, conflicting with the aim of harmonisation advocated by European authorities and the co-legislators.
Read full response here.
