SRB publishes its Annual Work Programme 2026

RegCORE Client Alert | Banking Union

QuickTake

Every year, usually during the fourth quarter, the Banking Union relevant authorities, comprised of the European Central Bank (ECB), acting at the helm of the Single Supervisory Mechanism (SSM) and the Single Resolution Board (SRB), at the steering wheel of the Single Resolution Mechanism (SRM), individually publish their Annual Work Programmes (AWPs) setting out their priorities and resourcing for the coming calendar year. The SRB’s AWP aims to foster cross-sectoral regulatory consistency and supervisory convergence and is thus of relevance to national competent authorities (NCAs) and national resolution authorities (NRAs) and more importantly the relevant firms within the scope of the SRB’s and the NRAs’ regulatory and supervisory mandates. 

On 26 November 2025, the SRB published its 60-page AWP outlining its key priorities for 2026.Available here.Show Footnote Building on its “SRM Vision 2028” strategy (which is itself subject to a planned “mid-term review”),See EU RegCORE analysis here.Show Footnote the SRB’s 2026 priorities include: (i) rolling roll out a revamped resolvability assessment and a new multi annual testing framework; (ii) simplifying resolution planning to enable more testing in close coordination with the NRAs; (iii) operationalising resolution tools and the operational readiness of the Single Resolution Fund (SRF); and (iv) sustaining crisis readiness through deep dives, expanded on-site inspections (OSIs) and training, streamlined decision making, accelerated digital adoption as well as supporting the EU debate on simplification and competitiveness and hosting the SRB’s inaugural economic conference on resolution related economic issues.

In addition to the AWP, the SRB on 1 December 2025 published a list of upcoming consultations and requests to the industry for 2026.Available here.Show Footnote The list for 2026 reflects the industry's overall resolvability progress and the SRB's commitment to simplifying practices and limiting the burden on the banking sector. From 2026 onwards, many bank-specific deliverables previously requested annually will be requested only in specific instances (e.g., due to remaining gaps in overall resolvability or when information from previous submissions becomes materially outdated). 

This Client Alert examines the key issues and regulatory considerations for market participants. For a complete picture, it should be read alongside our analyses of the 2026 work programmes from the European Commission, the ECB-SSM, the EU’s Anti-Money Laundering Authority and the European Supervisory Authorities (ESAs), the European Banking Authority (EBA), European Securities and Markets Authority (ESMA) and European Insurance and Occupational Pensions Authority (EIOPA), both individually and through their Joint Committee (JC). Readers may also find value in other publications from PwC’s Risk Network and PwC Legal’s “Navigating 2026," an annual outlook on the regulatory and supervisory agenda.

Key takeaways from the SRB’s 2026 AWP

The 2026 AWP signals a shift from designing frameworks to executing them, building on the “SRM Vision 2028” strategy. The SRB will implement a multi-year testing framework based on EBA guidelines, expand crisis simulations and OSIs and apply information and communication technology (ICT) and data tools to crisis and planning.

Resolution planning will be simplified and made more crisis-oriented. This will be achieved by embedding "crisis repositories" into Internal Resolution Team (IRT) workflows and increasing automation via enhancements to the Integrated Resolution Information System (IRIS) platform. Resolvability assessments will adopt a new Heatmap methodology, supported by rolling three-year testing programmes and more deep-dives on operational continuity in resolution (OCIR), liquidity-in-resolution and separability.

The SRF agenda focuses on verifying its target level, ensuring levy readiness and conducting dry runs, which may include an exercise with the European Stability Mechanism (ESM) common backstop. The SRB will also advance its digital transformation via its Digital Transformation Group (DTG) and Innovation Lab, improve its Data Quality Framework and strengthen governance across the SRM.

The SRB’s 2026 agenda is also shaped by the evolving regulatory, economic and geopolitical landscape. The board is actively engaged in policy discussions concerning the Crisis Management and Deposit Insurance (CMDI) framework, macroprudential reviews, digital finance (DORA, MiCAR, digital euro) and alignment with the Insurance Recovery and Resolution Directive (IRRD) and anti-money laundering (AML) reforms.

The 2026 AWP provides a roadmap for strengthening the EU’s crisis management and bank resolution framework. It also details the SRB's “Expectation for Banks” (EfB), which sets out the capabilities banks must demonstrate to be considered resolvable.
The 2026 AWP is structured around three strategic areas: (i) Core Business, (ii) SRB’s Governance, Organisation and Tools and (iii) SRB’s Human Resources. Each area is supported by specific objectives and key performance indicators to measure progress.

1. Core Business: Crisis preparedness, resolution planning and reference leadership

• Crisis preparedness and management: The SRB will operationalise a newly developed multi-annual testing framework, in line with EBA guidelines and setting a rolling, bank‑specific three‑year test programme, to ensure banks’ resolvability capabilities are effective and sustainable.  This includes comprehensive dry runs (with a strong emphasis on the Sale of Business tool), OSIs and the implementation of revamped resolvability assessments plus “standardised crisis days” in close cooperation with NRAs.  The SRB will update and integrate key ICT and business tools for crisis execution, including R4C, the valuation tool, the bail‑in calculator, PIA tooling and liquidity monitoring and it will scale crisis‑readiness training in communications, valuation and liquidity.  Documentation and “flashcards” migrate to interactive platforms, positioning crisis artefacts for real‑time use rather than static reference.
• Resolution planning and resolvability: The SRB will continue to streamline the annual Resolution Planning Cycle (RPC), focusing on actionable and simplified resolution plans. The 2026 RPC will prioritise separability, transferability, bail-in operationalisation and operational continuity in resolution, with enhanced Management Information System (MIS) capabilities. The SRB will refine plan templates based on 2025 lessons, embed “crisis repositories” within IRT processes and enhance automation via IRIS to reduce drafting load and accelerate updates of plans and MREL decisions. The 2026 priority letters focus on separability and transferability, bank testing of bail‑in operationalisation, OCIR with a specific focus on MIS capabilities and bank‑specific priorities. The SRB expects to adopt 105 plans within the 2026 cycle. Oversight of Less Significant Institutions (LSIs) will be reinforced, with a focus on consistent application of resolution standards and operational readiness across Member States.
• Oversight of LSIs: The SRB continues its LSI oversight function, emphasising consistent SRM standards across jurisdictions. It will deepen cooperation with NRAs, integrate lessons from the 2024 SRB-led LSI dry run and organise targeted LSI mini dry runs. Full LSI planning coverage is expected to continue in 2026, with around 1,845 LSIs covered in 2025 and broadly similar volumes ahead and a focus on approximately 70 LSIs earmarked for potential resolution. Group parents with LSI networks should ensure LSI playbooks are scaled, realistic and supported by shared-service arrangements that are resolution-robust, particularly for MIS, liquidity execution and OCIR.
• Single Resolution Fund – renewed readiness and testing: The SRB will verify the SRF's target level in Q1 2026, stay prepared to raise contributions if needed and run dry runs on its application. An ESM–SRB dry run may be organised to test the common backstop. Treasury and legal teams should be aware of SRF procedures and prepare for rapid engagement.
• SRM as a 'Reference in the Resolution Field': The SRB aims to establish the SRM as a leading authority on bank resolution. Initiatives include launching the first SRB Economic Conference and increasing collaboration with academia. The SRB will also contribute to key regulatory initiatives, such as the CMDI framework, IRRD and digital finance regulations (DORA, MiCAR).

2. SRB’s Governance, Organisation and Tools: efficiency, digital transformation and data capabilities

• Strengthened governance and streamlined structure: The SRB will simplify internal decision-making, enhance cooperation with NRAs and standardise practices to increase efficiency and transparency. It also plans to review its ethical framework and pilot 360 degree performance reviews.
• Digital transformation and best-practice technologies: Digital transformation is a flagship of SRM Vision 2028. For 2026, the SRB will scale the Digital Transformation Group, test and evaluate Innovation Lab Proofs of Concept and operationalise the Data Quality Framework. It will enhance scenario modelling, workflow automation and data analytics, improve interoperability with the ECB and NRAs and upgrade core applications supporting crisis management (R4C) and planning (IRIS). The SRB will continue strengthening cybersecurity, infrastructure resilience and end to end system monitoring, while pursuing best practice data governance across the SRM. Practically, institutions should expect heightened scrutiny of data lineage, timeliness and integrity across liability data, MIS for valuation and liquidity and reporting used in Heatmap and testing. Anticipate new or refined templates and higher bars for “valuation ready” and “liquidity ready” data. Cybersecurity will be reinforced through the implementation of a new ICT Cybersecurity Framework and compliance with the EU Cybersecurity Regulation.
• Operational efficiency and environmental sustainability: The SRB will invest in upgraded document management, financial planning and audit management platforms, as well as environmental management systems to promote sustainability in its operations.

3. SRB’s Human Resources: talent, learning and inclusion

• Motivated and professional workforce: The SRB will continue to develop its talent management strategy, promoting internal and external mobility, career development and staff well-being.  Recruitment efforts will be supported by a new HR communication plan and enhanced employer branding.
• Learning and development: The learning and development programme will be updated based on a skills gap analysis, focusing on continuous professional growth and a common training curriculum for SRB and NRA staff.
• Diversity and inclusion: The SRB will implement targeted diversity and inclusion initiatives, including awareness campaigns and measures to foster a respectful and inclusive culture.

Key regulatory and policy developments

The SRB’s 2026 AWP is set against a backdrop of geopolitical uncertainty and ongoing EU regulatory reforms. Key developments relevant to the SRB's work in 2026 include:

• Finalisation and implementation of the CMDI framework and IRRD.
• Review of the EU’s State Aid framework for banks and potential alignment with resolution rules.
• Ongoing initiatives to simplify and streamline banking regulation, enhance competitiveness and complete the Banking Union.
• Increased focus on digitalisation, operational resilience (DORA) and the integration of new technologies in financial services.
• Continued monitoring and contribution to macroprudential framework reviews and anti-money laundering initiatives. 
  Performance measurement and resource allocation

The SRB has established a detailed set of key performance indicators (KPIs) across its strategic objectives, covering areas such as crisis preparedness, resolvability, knowledge management, governance efficiency, digital transformation, staff engagement and diversity.

Planned resource allocation for 2026 reflects the SRB’s commitment to its core business, governance and support functions, with a total staff complement of 533 and a budget structured to support operational priorities and innovation.

The SRB's focus for 2026 is on action and evidence. Banks will be expected to demonstrate that their resolution capabilities are executable under realistic timelines. Testing outcomes, OSI findings and Heatmap results will directly influence supervisory dialogue and potential remediation measures.

Thematic items driving supervisory engagement and key impacts for firms

Thematic priorities that will drive supervisory engagement

The following thematic items are likely to drive SRB supervisory engagement in 2026:

Liquidity and funding in resolution
Banks will be expected to build capabilities for liquidity and funding in resolution, aligned with the SRB’s principles. This includes stress-testing cashflow projections, mobilising collateral and accessing central bank facilities. Firms should be able to demonstrate intraday visibility, contingency funding plans and readiness to interface with the SRF.

Operational continuity in resolution (OCIR)
OCIR remains central, with explicit focus on ICT risks and critical third-party providers given DORA driven changes to the Bank Recovery and Resolution Directive (BRRD) resolvability assessment. Expect deeper analysis of contractual resilience, termination/assignment/step-in rights, data portability and exit strategies. The SRB will provide targeted support to OCIR tests within the new testing framework.

This increases the importance of supplier governance and contract remediation. Banks should update service inventories, embed resolution compatible clauses in contracts and rehearse transfers based on transitional services agreements.

ICT and cyber risk in crisis
The SRB and NRAs will continue assessing how ICT incidents (e.g., cyber attacks, core systems failure) interact with crisis management and resolution, incorporating DORA incident reports into resolvability judgements. IRTs will integrate digital resilience evidence into Heatmaps.

Recurrent major incidents without demonstrable remediation will weigh on resolvability. Institutions should ensure cyber business continuity plans align with resolution playbooks, including secure data rooms, fallback payment and identity controls and safe to operate states during bail in or transfer weekends.

Valuation in resolution
Following public consultation, the SRB’s “Expectations on Valuation Capabilities” will be published around late 2025/early 2026, setting minimum data requirements (Valuation Data Index), a Data Repository for Resolution and governance/process expectations in Valuation Playbooks. 2026 will emphasise MIS capabilities to deliver day 1/2 and open bank valuations within tight timelines.

This requires banks to have auditable, automated data pipelines with clear data lineage, as well as playbooks aligned with the needs of external valuers, proven through time boxed dry runs.

Separability, transfer tools and combinations
Separability work will continue to support various resolution tools, including Sale of Business, bridge banks and asset separation, providing flexible and proportionate options.

Firms should conduct realistic separability analyses, define perimeters, segregate data, map regulatory permissions and draft rapidly-activated Transitional Services Agreements (TSAs) and Service Level Agreements (SLAs).

Public Interest Assessment (PIA)
The SRB will maintain risk based PIA updates for planning and crisis scenarios and assess the impact of CMDI reforms on PIA policy. Banks must keep their PIA data current and be prepared to revise assessments as CMDI rules are finalised.

MREL and quality assurance
The SRB will continue to conduct ex-post eligibility checks and monitor adherence to MREL targets. If shortfalls hinder resolvability, the SRB may impose formal measures, such as restrictions on distributions.

Firms should prioritise robust legal structuring and liability management to prevent eligibility disputes. This includes ensuring contractual recognition of bail in, proper subordination, clean holding company structures and resolving legacy intercompany entanglements.

Oversight of LSIs and cross sector touchpoints
The SRB will maintain full LSI planning coverage and help NRAs operationalise plans through targeted dry runs. Banks with significant clearing roles at Central Counterparties (CCPs) should monitor CCP resolvability developments. Insurance groups should track IRRD implementation and its effect on banking group plans.

Key impacts for firms

Firms face immediate legal and operational impacts. Resolution playbooks must be execution‑ready, with capabilities for rapid data extraction, liquidity dashboards, tested bail-in tools and robust operational continuity arrangements. Banks should expect tests of their live data and decision-making speed, not just reviews of policy documents.

Boards should expect a shift from narrative documents to practical, execution-ready tools. These include updated playbooks, data repositories for valuation, tested liquidity mobilisation scripts and pre‑drafted communications.

Further impacts include the following:

For Significant Institutions (SIs)
SIs should expect more assertive and granular testing. On-site inspections and deep dives will focus on bail in operationalisation, liquidity in resolution, MIS/valuation and OCIR. Resolvability self assessments must align with the revised methodology and Heatmap framework. MREL scrutiny will remain intense, with eligibility quality as important as nominal levels.

For LSIs
LSIs designated for resolution will face higher expectations on the practical operability of their plans. Targeted dry runs and closer SRB involvement in NRA oversight will test OCIR, MIS and liquidity execution.

For all institutions
Data quality, valuation capability, digital operational resilience and contractual resilience are now central to resolvability judgments. Firms should track the finalisation of CMDI and update their planning artefacts accordingly.

Firms should consider prioritising the following actions in 2026:

• Run internal dry runs aligned to the SRB’s multi annual testing framework, evidencing end to end execution for bail in, liquidity, OCIR and separability and producing artefacts that withstand OSI scrutiny and feed favourably into the Heatmap.
• Enhance MIS and valuation capabilities by creating a valuation ready data repository and testing valuation packages under time pressure.
• Maintain credible, stress resilient MREL strategies and resolve eligibility weaknesses; prepare contingency pathways if market access tightens.
• Update OCIR documentation, focusing on critical ICT suppliers and DORA aligned contractual controls and rehearse service continuity.
• Assess cross border separability and transferability to ensure resolution tools are not constrained by regulatory frictions.
• Align early intervention, PIA and crisis management playbooks with evolving CMDI expectations and SRB crisis documentation formats.
• Prepare for deeper data quality and governance reviews consistent with the SRB’s digital strategy and ensure technical teams are resourced for frequent, time critical supervisory data pulls.

Applying the above and viewing it through a legal lens, regulated firms should prioritise a coordinated upgrade of contractual “readiness clauses” and policy frameworks that directly support execution under SRB timelines. This may include the following:

• OCIR contract suite. Refresh service critical intra group and third party agreements to be resolution compatible: assignment/novation and step in rights, non termination/change of control carve outs for resolution events, minimum service levels during transfer/bridge phases, data portability and segregation obligations, IP licences (with escrow/source code and access keys) and robust exit/transition assistance schedules (TSAs/SLAs, service descriptions, pricing and change control). Align with DORA by embedding audit, testing, resilience, major incident reporting, subcontracting controls and location/access rights for authorities.
• Critical ICT/outsourcing addenda. Implement DORA aligned addenda across cloud and strategic vendors: security baselines, incident response cooperation, penetration testing/Red Team rights, business continuity commitments including Recovery Time and Point Objectives (RTO/RPO), termination assistance, data residency and cross border transfer mechanics and explicit recognition of resolution authority access and information rights. Ensure portability/readiness for rapid re hosting or temporary run state during a transfer weekend.
• Bail in and securities documentation. For third country law liabilities, ensure robust contractual recognition of bail in and stays; cleanse legacy terms that risk acceleration/set off on entry into resolution; confirm subordination and clean holdco features for MREL eligibility; update fiscal agency, paying agent and clearing system notices/playbooks for accelerated communications and booking entries. Maintain liability management and disclosure scripts to support market/stakeholder messaging during execution.
• Liquidity in resolution enablers. Pre agree collateral and liquidity lines documentation (CSAs, tri party, pledge and title transfer structures) with eligibility representations aligned to central bank frameworks; maintain contingency templates for emergency facilities and SRF interfacing (including authorisations, representations and conditions precedent) to enable same day draw.
• Separability and transfer readiness. Maintain buyer facing document packs: perimeter definitions and asset schedules; assignability/consent matrices; employee transfer clauses and works council engagement pathways; customer communication templates; IP and data licensing/assignment mechanics; and pre negotiated TSAs. Map regulatory permissions and notification/approval steps with jurisdiction specific annexes.
• Financial Market Infrastructure (FMI) and trading documentation. Align with recognition of resolution stays (e.g., via protocols from the International Swaps and Derivatives Association (ISDA), International Capital Market Association (ICMA) and International Securities Lending Association (ISLA)) across derivatives, repo and securities lending; ensure closeout/modification mechanics do not frustrate tool selection. Review agreements with Central Securities Depositories (CSDs), Central Counterparties (CCPs) and other banking infrastructure for portability, continuity of access and step in arrangements by a bridge institution or transferee.
• Data, valuation and confidentiality. Hard wire access and extraction rights in vendor and intercompany contracts to populate the Valuation Data Repository; include regulatory/valuer disclosure carve outs, data retention and permitted use clauses to support day 1/2 and open bank valuations. Put in place ready to use NDAs and data room rules tailored to resolution timelines.
• Cross border recognition. Expand use of contractual recognition of resolution powers and stays with third country counterparties; include cooperation clauses facilitating information sharing with foreign authorities and operational steps for branch/booking model transfers.
• Authority and signatures. Prepare weekend execution authority packs: board resolutions, delegated authorities, notarisation/apostille contingencies, Powers of Attorney (PoAs) and specimen signatures to complete transfers, novations and capital measures at speed.
• Policy framework updates. Update and secure board approval for policies and playbooks that anchor execution: OCIR policy and service inventory standard; third party risk/outsourcing policy (DORA aligned); liquidity in resolution policy and SRF interface Standard Operating Procedure (SOP); valuation policy and playbook with data governance standards; separability and transfer playbook; early intervention/crisis governance and decision trees; PIA methodology; MREL management policy (covering issuance, monitoring, waivers and eligibility controls); and crisis communications/disclosure policy.
• Governance, assurance and repositories. Maintain a clause library and contract registry tagged to resolvability requirements and Heatmap gaps; embed pre signing checks in procurement/treasury issuance to enforce resolution ready terms; evidence periodic legal testing (table top and dry run sign offs) and formal closure of remediation findings.

Cross‑functional alignment across legal, treasury, finance, IT, HR and service companies is critical, as testing will surface practical frictions in crisis choreography.

Outlook

The SRB’s 2026 AWP signals a period of consolidation and innovation in the EU’s bank resolution framework. Market participants should anticipate increased supervisory scrutiny of crisis preparedness, resolvability and digital resilience, as well as ongoing engagement with regulatory reforms and policy debates.  The SRB’s focus on operational readiness, digital transformation and stakeholder engagement is designed to ensure the continued stability and resilience of the EU banking sector in a rapidly evolving environment.

For firms, 2026 is an action year: strengthen capabilities, evidence them through testing, remediate findings decisively and be prepared for more intrusive and frequent supervisory dialogue at the level of IRTs, NRAs and in some areas with the SRB directly. Firms are encouraged to monitor SRB communications and participate in consultations and industry events to remain aligned with evolving expectations and best practices in resolution planning and crisis management.

About us

PwC Legal is assisting a number of financial services firms and market participants in forward planning for changes stemming from relevant related developments. We have assembled a multi-disciplinary and multijurisdictional team of sector experts to support clients navigate challenges and seize opportunities as well as to proactively engage with their market stakeholders and regulators.  

Moreover, we have developed a number of RegTech and SupTech tools for supervised firms, including PwC Legal’s Rule Scanner tool, backed by a trusted set of managed solutions from PwC Legal Business Solutions, allowing for horizon scanning and risk mapping of all legislative and regulatory developments as well as sanctions and fines from more than 2,500 legislative and regulatory policymakers and other industry voices in over 170 jurisdictions impacting financial services firms and their business.  

Equally, in leveraging our Rule Scanner technology, we offer a further solution for clients to digitise financial services firms’ relevant internal policies and procedures, create a comprehensive documentation inventory with an established documentation hierarchy and embedded glossary that has version control over a defined backward plus forward looking timeline to be able to ensure changes in one policy are carried through over to other policy and procedure documents, critical path dependencies are mapped and legislative and regulatory developments are flagged where these may require actions to be taken in such policies and procedures.   

The PwC Legal Team behind Rule Scanner are proud recipients of ALM Law.com’s coveted “2024 Disruptive Technology of the Year Award” as well as the “2025 Regulatory, Governance and Compliance Technology Award”. 

If you would like to discuss any of the developments mentioned above, or how they may affect your business more generally, please contact any of our key contacts or PwC Legal’s RegCORE Team via de_regcore@pwc.com or our website.