The European Banking Authority has issued a no-action letter and technical considerations to support the implementation of the revised market risk framework for EU banks, pending the entry into force of the European Commission’s Delegated Act.
The European Banking Authority (EBA) has published a no-action letter regarding the boundary between the banking book and the trading book. It also shared technical clarifications related to the European Commission’s Delegated Act that modifies the calculation of own funds requirements for market risk based on the Fundamental Review of the Trading Book (FRTB) framework.
The measures aim to ensure a consistent and harmonised implementation of the revised framework across the European Union (EU). The Delegated Act is currently under review by the European Parliament and the Council and will become relevant once it enters into force.
In its no-action letter, the EBA recommends that competent authorities do not prioritize supervisory or enforcement actions related to the boundary between the trading and banking books and certain reporting requirements. This guidance helps avoid operational complexity and level-playing-field concerns, especially for institutions applying the institution-specific multiplier introduced by the Delegated Act.
The EBA also provides technical considerations on key implementation issues and clarifies the treatment of institutions for supervisory benchmarking purposes.
The no-action letter is issued under Article 9c of Regulation (EU) No 1093/2010 (EBA Founding Regulation). The Delegated Act, adopted on 4 June 2026 under Regulation (EU) No 575/2013 (CRR), will modify market risk requirements from 1 January 2027 for three years. The aim is to facilitate a smooth, consistent, and proportionate implementation of the revised framework across the EU.
