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D-SIB designation and capital surcharges

D-SIB designation and capital surcharges

The European Banking Authority (EBA) has published its first EU-wide list of nationally designated Domestic Systemically Important Banks (D-SIBs) – termed Other Systemically Important Institutions (O-SIIs) in CRD4 – and the additional capital buffers (to be phased in between 2016 and 2019) that national competent authorities have set for their D-SIBs.


Senior Advisor, EMA FS Risk & Regulatory Insight Centre

KPMG in the UK


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This list also provides a good indication of which banks are likely to receive enhanced supervisory and resolution planning oversight.  It will be updated each year.

The D-SIB capital surcharge is of particular importance because banks are expected to meet it at all times – unlike the capital conservation buffer and any counter-cyclical capital buffer, which are expected to absorb losses during severe downturns.  Banks that are part of a Global Systemically Important Bank (G-SIB) banking group are expected to meet the higher of the G-SIB surcharge and any D-SIB surcharge.

The list indicates some areas of divergence of approach across countries:

  • Most countries appear to have applied strictly the December 2014 EBA guidelines for identifying O-SIIs.  Some, however, have made use of the local supervisory judgement option to designate a wider range of banks as D-SIBs – and therefore the list is not strictly comparable across the internal EU boundaries.
  • In Germany, 11 out of 16 D-SIBs have been included on the basis of supervisory judgement; 8 out of 16 in the UK; 3 out of 9 in Hungary; 2 out of 6 in Denmark; and 2 out of 7 in Austria.
  • Most countries have applied a range of capital surcharges to their D-SIBs, reflecting the extent of their domestic systemic importance (following the Basel Committee approach to G-SIBs).  However, a few countries have applied the same capital surcharge to all their D-SIBs: Norway (2%), Sweden (2%), Greece (1%), and Romania (1%).
  • For some banks the D-SIB surcharge is higher than the G-SIB surcharge applied to the global banking group (for example ING and Nordea with a 2% D-SIB surcharge against a 1% G-SIB surcharge), and in some cases it is lower (for example, BNP Paribas with a 1.5% D-SIB surcharge against a G-SIB surcharge of 2%).
  • Some countries have not (yet) applied any capital surcharge to their D-SIBs: the UK, Italy and Latvia. In the UK this is because the only use of a bank-specific systemic risk buffer is for ring-fenced retail banks.
  • In some countries the D-SIB buffer is in addition to banking sector wide systemic risk buffers: in Norway and Sweden banks are subject to a separate 3% systemic risk buffer (D-SIBs have to meet this in addition to their 2% D-SIB capital surcharge). This is an example of how both the D-SIB buffers and the varying use of macro-prudential instruments across countries is driving sharp differences in minimum capital requirements across banks in Europe.
  • Supervisory authorities continue to struggle to determine the extent – if any - to which D-SIB capital surcharges might be offset to some extent by lower Pillar 2 capital requirements.            

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