A quarterly, public-data read on how much CET1 headroom European G-SIBs hold above the Maximum Distributable Amount (MDA) trigger — the figure that gates AT1 coupons, dividends, share buy-backs and variable remuneration. Calibrated from FY2025 Pillar 3 disclosures, EBA risk-indicator tables and published SREP P2R levels. Methodology at the foot of the page.
Headroom is the cushion between a bank’s reported CET1 ratio and the CET1 threshold below which the Maximum Distributable Amount rules automatically restrict distributions. The headroom number — not the absolute CET1 ratio — is what a CRO is asked about in every board meeting and every JST dialogue. Methodology and sources at the foot of this page.
For each bank in the cohort below we compute an illustrative MDA trigger as the sum of Pillar 1 CET1 minimum, the combined buffer requirement (CBR) — conservation, G-SII or O-SII, countercyclical, systemic risk — and the CET1 component of Pillar 2 Requirement (P2R) as published in the latest SREP decision letter or Pillar 3 disclosure.
Pillar 2 Guidance (P2G) sits above the MDA trigger and is not part of the automatic distribution restriction, although a breach of P2G triggers heightened supervisory dialogue and can shape the next SREP cycle.
FY2025 Pillar 3 basis. Illustrative. Reported CET1 ratios are as disclosed by each bank in its FY2025 annual Pillar 3 report. Illustrative MDA triggers are Ezelman calculations from the components above, using the bank’s disclosed G-SII / O-SII buffer and the most recently published P2R. The headroom column is the difference. All figures should be verified at source for any decision-bearing use.
| Bank (home supervisor) | FY2025 CET1 ratio | Illustrative MDA trigger | Illustrative headroom |
|---|---|---|---|
| BNP Paribas (ECB / ACPR) | 13.2% | ~10.3% | ~290 bps |
| Deutsche Bank (ECB / BaFin) | 13.8% | ~10.6% | ~320 bps |
| Banco Santander (ECB / Banco de España) | 12.9% | ~9.8% | ~310 bps |
| UniCredit (ECB / Banca d’Italia) | 16.1% | ~9.5% | ~660 bps |
| Intesa Sanpaolo (ECB / Banca d’Italia) | 13.9% | ~9.7% | ~420 bps |
Note. The cohort above is restricted to the five European G-SIBs for which FY2025 Pillar 3 CET1 ratios are reproduced from public disclosures in Ezelman’s calibration pack. ING, Crédit Agricole, Société Générale, Nordea and BPCE publish comparable FY2025 ratios and will be added in the Q3 2026 edition once the 2026 SREP cycle P2R notifications are public. Figures rounded to one decimal place for legibility.
CET1 headroom is a moving figure. The three biggest drivers for 2026 are: (i) CRR3 first-time-adoption RWA uplift (tracked separately in the CRR3 Impact Index), which mechanically lowers the ratio on 1 January 2025 and the output-floor-driven re-rating that phases in thereafter; (ii) the 2026 SREP cycle P2R recalibration, which can add or remove 25–75 bps to the MDA trigger on a bank-by-bank basis; and (iii) the adverse outcome of the 2027 EBA EU-wide stress test, which flows into 2028 P2G through the ECB’s bucketed framework and therefore does not bite MDA immediately — but which supervisors read alongside headroom when judging whether a bank’s payout plan is compatible with its risk profile. See the Ezelman walk-through on how supervisors read stress-test output and on P2G formation logic.
The CET1 Headroom Tracker is an illustrative reference built from three public-data streams and triangulated with the published SREP architecture. It is not a recommendation and not a credit opinion. Every number above is either (a) drawn directly from a bank’s FY2025 Pillar 3 report, (b) an Ezelman calculation from those disclosed inputs, or (c) explicitly labelled as an illustrative range.
Sources. (i) The FY2025 annual Pillar 3 reports and annual-results press releases of each listed bank — CET1 ratio, G-SII / O-SII buffer, and most recently disclosed P2R; (ii) the EBA risk-indicator tables (quarterly) and the ECB supervisory statistics for aggregate cohort benchmarking; (iii) the ECB’s aggregate SREP statement (annual) for the distribution of P2R across the SSM population.
Assumptions. Where a bank has not yet disclosed its 2026 P2R notification we use the FY2025 level. Where a bank discloses total P2R but not the CET1 split we assume the regulatory default (56.25% of total P2R must be met in CET1, per Article 104a CRD). Countercyclical buffer rates are blended from the jurisdiction-weighted average published by each bank; the systemic risk buffer is taken from the relevant Member State designation as of 1 April 2026.
What we do not do. We do not publish Ezelman client-mandate headroom figures or CRO pipeline forecasts. Those are held under mandate and are not reproduced here, consistent with our sitewide public-data policy: every figure on ezelman.com is either public-sourced, an estimate with stated methodology, or qualitative.
Deeper analysis. The ECB-style bucketing of banks into “low”, “medium” and “high” P2G categories based on stress-test output, the jurisdiction-level P2R distribution, and the interaction between headroom and AT1 coupon risk is released to Ezelman Intelligence subscribers.
Next edition: Q3 2026, published after the ECB SREP communication window in late September.