ECB Streamlining of Supervisory Guidance: What Survives, What Gets Rewritten
On 26 June 2026 the ECB announced the outcome of a review of roughly 130 supervisory guides, reports, letters and methodologies. Around 40 are discontinued as outdated, superseded or no longer relevant — they stay accessible, labelled as discontinued. A handful of guides get targeted revisions immediately, and five substantial rewrites land between Q3 2026 and Q1 2027 — including the Guide to On-Site Inspections and Internal Model Investigations. If your remediation programme cites an ECB guide by chapter, this is the moment to check which document you are anchored to.
Three moves in one announcement
The 26 June package is not a single document — it is a portfolio decision on the whole supervisory library. Three distinct moves, each with a different operational consequence for banks.
~40 publications discontinued
Identified as outdated, superseded or no longer relevant. They remain accessible on the ECB site, labelled as discontinued — so a citation trail survives, but the expectation no longer stands.
Targeted revisions, effective now
Management-buffer guidance clarified in the ICAAP guide. Credit-conversion-factor content removed from the Guide to Internal Models pending EBA guidelines. CVA references removed from the assessment-methodology and materiality guides, reflecting CRR3.
Reclassification as non-binding
Supervisory publications are reclassified to make their non-binding nature explicit and consistent across the library. A legal-form change — not, in our reading, a change in what JSTs will actually test against.
Nearly a third of the ECB’s supervisory library is being retired
Of roughly 130 publications reviewed, around 40 are discontinued outright and five of the remaining core guides are queued for substantial rewrite by early 2027. The library your last remediation plan cited is not the library the next inspection will use.
Source: ECB Banking Supervision, “ECB streamlines supervisory guidance”, press release, 26 June 2026. Counts as stated by the ECB (approximate).
The rewrite pipeline: Q3 2026 to Q1 2027
Five substantial revisions are announced with target dates. Two of them — the OSI/IMI guide and the risk-data guide — sit directly underneath live remediation and inspection-preparation programmes.
Four consequences worth acting on before year-end
The OSI guide is being rewritten before the 2027 inspection cycle
Any bank in the ECB inspection pipeline (the ECB launched 163 on-site inspections and 77 internal model investigations in 2025, per its Annual Report on supervisory activities published in March 2026) should track the end-2026 revision of the Guide to On-Site Inspections and Internal Model Investigations. Inspection-readiness work calibrated to the current guide needs a delta review when the new text lands — scope, interaction rules and follow-up mechanics are exactly where revisions bite.
Do not anchor BCBS 239 remediation to the current RDARR text
The risk-data guide is revised in Q4 2026. Multi-year RDARR remediation plans that cite the current guide chapter-and-verse should build the revision into their design assumptions now, not re-paper the programme in 2027.
“Non-binding” is legal form, not supervisory relaxation
The reclassification makes explicit what was always the legal position. JSTs will keep testing practices against the guides in SREP and on-site work. Treat the label as positioning for judicial review — not as a reason to deprioritise alignment.
A CCF guidance vacuum until the EBA delivers
CCF content is removed from the Guide to Internal Models pending EBA guidelines. Until those land, the binding reference for CCF treatment is the CRR3 text and the EBA’s final RTS package — see our CCF deep-dive for where the capital moves.
Primary documents cited in this analysis
- [1]ECBECB Banking Supervision — press release on the streamlining of supervisory guidance, 26 June 2026 → source
- [2]EURegulation (EU) 2024/1623 (CRR3) — Official Journal of the European Union, 19 June 2024 (basis for the CVA-reference removals) → source
Dates, paragraph numbers and document versions verified at publication. Where consultations are still open, we flag draft status in text. Corrections: research@ezelman.com.
This analysis underpins our OSI-readiness and RDARR mandates.
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