The European Banking Authority has launched a public consultation on three draft Regulatory Technical Standards governing the reclassification of investment firms as credit institutions when their total assets exceed 30 billion euros.
Threshold Calculation and Regulatory Scope
Under the Capital Requirements Directive, investment firms that cross the threshold of 30 billion euros in total assets are required to obtain credit institution authorisation rather than continuing under a MiFID investment firm authorisation.
Following amendments made to the Capital Requirements Directive in 2024, the European Banking Authority updated its draft methodology for calculating total assets at solo and group levels. These revised standards clarify the precise scope of entities included in asset threshold calculations.
Reporting Framework and Authority Waivers
The consultation covers reporting obligations established under the Investment Firms Regulation, which mandates reporting for investment firms with total assets exceeding 5 billion euros.
For the first time, the regulator is consulting on technical standards that define the criteria competent national authorities must evaluate when considering a waiver. If granted, the waiver permits an eligible firm to retain its investment firm authorisation instead of reclassifying as a credit institution.
Consultation Deadlines and Public Hearing
Stakeholders and interested parties can submit feedback on the consultation proposals until 25 November 2026.
A virtual public hearing is scheduled for 30 September 2026 at 10:00 CEST. Registration for the event closes on 25 September 2026 at 16:00 CEST.
