ECB publishes its SSM Annual Work Programme 2025
Written by
RegCORE Client Alert | Banking Union
QuickTake
Every year, usually during the fourth quarter, the Banking Union relevant supervisory authorities, comprised of the European Central Bank (ECB), acting at the helm of the Single Supervisory Mechanism (SSM) and the Single Resolution Board (SRB), acting at the helm of the Single Resolution Mechanism (SRM), individually publish their Annual Work Programmes (AWPs) setting out their priorities and resourcing for the coming calendar year and through to two years after. The ECB-SSM’s AWP for the period 2025-2027 (for simplicity hereinafter the 2025 AWP), aims to foster cross-sectoral regulatory consistency and supervisory convergence and is thus of relevance to national competent authorities (NCAs) and more importantly the relevant firms within the scope of ECB-SSM’s and NCAs’ Banking Union mandate as exercised by joint supervisory teams (JSTs).
On 17 December 2024, the ECB-SSM published its 2025 AWP. The document builds upon the goals of the previous AWP for the period 2024-2026, yet in 2025 focuses on readdressing key strategic priorities and implementation of new mandates.Available here.Show Footnote On the same day the ECB-SSM equally published a number of more detailed descriptions of the methodology for assessing the (i) market risk, (ii) credit risk, (iii) interest rate and credit spread risk in the banking book, (iv) the internal governance and risk management as well as the operational and information and communication technology (ICT) risk of those entities that for SSM purposes are designated as ‘significant institutions’ (SIs), as part of the ECB-SSM-run Supervisory Review and Evaluation Process (SREP) along with aggregated results of the 2024 SREP, details of which are assessed in a separate Client Alert. Importantly, on 13 December 2024, the ECB-SSM had equally published its 2024 Supervision Report setting out observations relating to those Banking Union supervised institutions (BUSIs) that for SSM purposes are categorised as ‘less significant institutions’ (LSIs).
This Client Alert discusses the key requirements and expectations as well as legal and regulatory considerations for relevant market participants as well as the key differences between the ECB’s 2025 AWP and that previously for the period 2024-2026. This Client Alert should be read together with other thematic deep dives on reforms and developments as well as our standalone analysis of all relevant 2025 AWPs from the SRB as well as the European Commission, the European Systemic Risk Board (ESRB), the European Supervisory Authorities (ESAs), comprised of the European Banking Authority (EBA), the European Securities and Markets Authority (ESMA) and the European Insurance and Occupational Pensions Authority (EIOPA) – both when acting individually as well as through the Joint Committee (JC) of the ESAs. Readers may also find benefit in consulting “Navigating 2025”, a comprehensive playbook providing a more granular annual outlook from PwC Legal’s EU RegCORE on the forthcoming regulatory policymaking agenda, the supervisory cycle and assessment of any commonalities and trends across plans for 2025 and beyond.
Key takeaways from the ECB-SSM’s 2025 AWP
As in previous years the ECB-SSM’s 2025 AWP has outlined an ambitious and comprehensive work programme for 2025, aimed at enhancing regulatory consistency, supervisory convergence and addressing identified vulnerabilities across the Banking Union. In summary the 16 pages of the 2025 AWP communicate the ECB-SSM’s requirements and expectations of BUSIs as well as improvements to the ECB-SSM’s functioning across the following three key priorities for 2025-2027:
Priority 1: Banks should strengthen their ability to withstand immediate macro-financial threats and severe geopolitical shocks – with a focus on the following vulnerabilities amongst BUSIs …
