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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 Around 40 are discontinued as outdated, superseded or no longer relevant — they stay accessible, labelled as discontinued.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.

~130
Supervisory guides, reports, letters and methodologies reviewed
~40
Publications discontinued — outdated, superseded or no longer relevant
5
Substantial rewrites due Q3 2026 – Q1 2027, incl. the OSI/IMI guide

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.

1

~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Identified as outdated, superseded or no longer relevant.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.

2

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.

3

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.

Reviewed ~130 Continue in force ~90 Discontinued ~40 Substantial rewrites due 5 · by Q1 2027

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.

Q3 2026
Guide to Licence Applications
Q4 2026
Guide on Risk Data Aggregation & Risk Reporting
End-2026
Guide to On-Site Inspections & Internal Model Investigations · Leveraged Transactions guidance
Q1 2027
Governance & Risk Culture — draft guide replaced by good-practices report

Four consequences worth acting on before year-end

A

The OSI guide is being rewritten before the 2027 inspection cycle

Any bank in the ~60-inspection ECB pipeline 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.

B

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.

C

“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.

D

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.

Preparing an inspection against a moving guide?

We run OSI readiness and RDARR remediation reviews against the supervisory text that will apply when the inspection team arrives — not the one it replaced. Senior-only, partner-led.

See the inspection practice →
Sources & references

Primary documents cited in this analysis

  1. [1]
    ECBECB Banking Supervision — press release on the streamlining of supervisory guidance, 26 June 2026 → source
  2. [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.

From analysis to mandate

This analysis underpins our OSI-readiness and RDARR mandates.

Partner-led, senior-only, no audit conflict. If the question in this piece is live at your institution, the first conversation is with a partner — not a BD team.

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