We have run the bank's side of the room. Scroll through the 120 days that decide whether the follow-up letter costs you capital, and what we do on each of them.
Governance, three lines of defence, model inventory, data lineage. If these are not standing at D-120, the inspection is already a remediation programme; our first week tells you which.
Ezelman estimate Range for a material SSM finding (F3 or F4). Illustrative, not supervisory guidance.
A full mock inspection sixty days before kickoff: evidence retrieval timed in hours, interviews rehearsed, one evidence taxonomy across credit, model, data and IT, every document pre-cleared by legal, risk and finance.
Foundations · Open dialogue · Readiness drill · Taxonomy · Response line · Evidence vault · Supervisory narrative · Sustain: eight positions held from D-120 to the follow-up letter. The FORTRESS method.
We sit in the room, on the bank's side: daily coordination with the inspection team, a real-time reading of every request, prioritisation and escalation. Every answer comes from the evidence vault; none is improvised.
Each finding gets four fields: the bank's position, a dated commitment with a named executive owner, a Board milestone, the evidence file. The inspection team accepted this structure at first review.
Our most recent IRB inspection closed in 2026: a European G-SIB, nine months from notification to close, under 20 findings in the draft report, two corrective action plans. P2R is set on the whole SREP, not per inspection, so the record covers only the inspected scope.
The remediation load is real: about 12,000 open supervisory measures across significant banks at end-2025, roughly 100 per bank (ECB, 6 October 2026).
Ezelman estimate Peer Pillar 2 add-on (a P2R effect), in bps of RWA, across inspections observed 2023 to 2025; no supervisory statistic is published.
An ECB inspection is decided before kickoff. We run the bank's side; on inspections we supported, no Pillar 2 add-on was attributable to the inspected scope.
If your data, governance or executive sponsorship is not ready, we tell you before the engagement, not after. If we cannot meet the standard, we recommend someone who can.
1 Senior-led mandates across the founder's career and Ezelman; Ezelman's own mandates since 2020 are on Recent Mandates. One partner; a bench of senior practitioners, Director level and above, engaged per mandate.
Typical mandates EUR 250k to 1.5m · senior-only delivery
Mandates for G-SIBs · SSM-supervised banks · GCC Tier-1 banks
Inspections show it most; the stress test, the CRR3 programme and the operating model run on the same method.
FORTRESS from D-120 to the follow-up letter: readiness drill, evidence vault, one response line, written comments that contest with evidence.
Stress testing and ICAAPProjection and template production for the 2027 EU-wide exercise, reverse stress testing as the artefact the JST reads first, ICAAP calibration the Risk Committee can defend.
Regulatory programmeGroup-wide CRR3 ownership from norms to permanent control; Art. 494d reversions; the SA-CR, CCF and IRB levers that still work after the 65 percent step in 2028.
Risk and finance transformationCost and RWA optimisation, data architecture, target operating model, post-merger integration across credit, market and operational risk.
In progress · 2026
The bank's side of a live ECB inspection at a European G-SIB: supervisor interactions, data requests, credit-file walkthroughs and the findings narrative to the exit meeting.
Stress testingThe 2027 EU-wide exercise for a European G-SIB: read-across of the EBA draft methodology, projections across credit, market and NII, QA and the supervisory dialogue.
Regulatory programmeA European G-SIB's corporate portfolios moving from A-IRB to F-IRB and standardised CCFs, with stress testing, ICAAP and IFRS 9 adapted.
Completed
A European G-SIB's CRR3 programme, owned across seven workstreams.
ECB on-siteThe bank's side of an ECB IRB inspection: 800+ requests, 95% answered within 48 hours, under 20 findings in the draft report.
Regulatory programmeThe framework assigning A-IRB, F-IRB or SA by exposure class, and the ECB package; sovereign, RGLA, PSE and central-bank classes notified under CRR Art. 494d.
Their on-site inspection expertise is practical, senior, and effective. They don't advise from the sidelines. They sit with you in the room, negotiate with the inspector, and own the findings line by line.Client, European G-SIB
Client references are available on request, with the client's consent.
All case studiesSix large EU banks, all SSM-supervised: four G-SIBs (BNP Paribas, Santander, Société Générale, Deutsche Bank) and two O-SIIs (BBVA, UniCredit). Four are on our CET1 headroom tracker today.
Deutsche Bank reports the second-highest CET1 ratio of these four and only the third-highest headroom.
Headroom is the FY2025 CET1 ratio less an illustrative CET1 MDA trigger: 4.5% Pillar 1 + the CET1 share of P2R + the combined buffer, from disclosed P2R and buffers. P2G sits above the trigger, outside it.
the H2 2026 refresh of the six-bank cohort read is in preparation on the Q2 2026 disclosure round; publication date to be announced.
EBA/CP/2026/18 under Art. 323(2) CRR, consultation open until 31 December 2026.
Jul 2026Radar · EBA / SREPEBA/GL/2026/06, final report of 26 June 2026, applies from 1 January 2027.
Apr 2026Essay · Pillar 2 / SREP · 12 minP2G is set from the supervisory stress test and sits above the MDA stack.
Readiness work pays most 6 to 12 months before kickoff; the 120 days before kickoff are the minimum. Already under inspection? We typically mobilise within 48 hours.
The founder on every call. Prefer to read first? Request the 2026-2030 Regulatory Thesis (8 pages, email required).
