An anonymised quarterly benchmark of ECB on-site inspection findings across Ezelman mandates — by portfolio type, finding severity, and year. The only public data set that tells European banks what their peers are actually being asked in the inspection room.
Industry benchmarks circulate in the 60–90 findings range. On Ezelman-supported inspections, the number is under 40 — because the 80 the bank would otherwise get are pre-empted during readiness.
Observed finding counts per inspection, rolling 4Q average, across Ezelman-supported ECB/SSM on-site inspections in 2024–2026.
| Theme | Ezelman-supported | Peer benchmark | Highest severity observed |
|---|---|---|---|
| IRB — PD model | 6.2 | 14.0 | F4 |
| IRB — LGD model | 5.8 | 12.5 | F4 |
| IRB — CCF & off-balance-sheet | 3.1 | 7.0 | F3 |
| IRB — data quality & lineage | 4.6 | 11.0 | F4 |
| IRB — model validation & monitoring | 4.9 | 10.5 | F4 |
| Credit risk — NPE classification | 2.3 | 6.2 | F3 |
| Credit risk — IFRS 9 staging & SICR | 3.8 | 9.0 | F4 |
| Counterparty credit risk — MPoR | 1.9 | 4.5 | F3 |
| Governance & documentation | 4.1 | 8.5 | F2 |
| Pillar 2 / ICAAP narrative | 1.7 | 4.0 | F2 |
Supervisory priority themes on live ECB OSI mandates — not what the SSM published in its Priorities document but what the inspectors are actually asking the bank.
Inspectors pushing back harder on downturn LGD adequacy — especially in real-estate-heavy portfolios. The 2008–2014 downturn window is being challenged as insufficient for book risk.
Re-litigation of the 2021 EBA RTS on material changes. Banks are discovering that many "non-material" refreshes were in fact material under the new thresholds.
New theme. Inspectors now asking to see Q1 2026 parallel runs during this year's inspections. Banks that haven't started have nowhere to hide.
The ECB publishes no finding-level statistics. The EBA's peer-review reports are two years lagged and polite. The Big Four have the data but do not publish it — because publishing it contradicts their premium-priced "ECB insider" pitch.
We publish it. Because once a bank sees that 11 findings on IFRS 9 staging is normal and 4 is possible, the conversation inside the bank changes. That conversation change is what we sell.
The full member-only tracker includes: bank-size-tier breakdown, country-by-country severity distribution, a rolling 3-year trend, and the top 20 "preventable" finding types with our fix playbook.