Consultation reciprocation Belgian macroprudential systemic risk buffer

Supervision consultation

The European Systemic Risk Board (ESRB) previously recommended reciprocating a macroprudential measure by the National Bank of Belgium, which DNB followed up on at the time. Recently, the ESRB amended its recommendation and advised applying the systemic risk buffer on an individual, sub-consolidated, and consolidated basis. DNB intends to follow this updated ESRB recommendation. Applying the reciprocated systemic risk buffer on the individual, sub-consolidated and consolidated bases helps prevent “leakage” and regulatory arbitrage. 

Published: 21 August 2025

Supervision consultation Open

This is an open Supervision consultation. You can respond until 22 September 2025.

The measure 

The measure consists of a systemic risk buffer of 6% on an individual, sub-consolidated, and consolidated basis for all IRB exposures related to natural persons that are secured by non-commercial real estate located in Belgium (including both defaulted and non-defaulted exposures). 

Applicability 

Due to reciprocity, this measure applies to the relevant exposures of subsidiaries and branches of Dutch credit institutions in Belgium, as well as to relevant cross-border exposures of Dutch credit institutions related to Belgium. An institution-specific threshold of €2 billion applies. The measure becomes binding once the relevant sectoral exposures of credit institutions exceed this threshold. The Belgian measure is applied pursuant to Article 133 of Directive 2013/36/EU (CRD). 

Further information 

More information about reciprocity and measures reciprocated by DNB is available here. 

More information about the measure and the ESRB’s recommendation to reciprocate it is available is here (links to an external site). 

Responses 

You may respond until the 22nd of September. Responses to the consultation can be submitted via the consultation form below. If you grant us permission, we will publish your response including your name and/or position. Without this permission, we will only publish the content of your response and, where applicable, the name of the organization—excluding your name and/or position. You may withdraw your permission by emailing consultatie@dnb.nl, which does not affect the lawfulness of the publication of your name and/or position prior to withdrawal. 

For other questions, you can also contact consultatie@dnb.nl. 

More information about how DNB processes personal data and your rights under the GDPR can be found in the privacy note.  

Finalization and publication of policy statement 

After receiving, weighing, and processing the consultation responses, DNB will decide on the finalization and publication of a definitive version of the consulted policy statement. DNB will communicate the outcomes of the consultation on dnb.nl, including a feedback statement in which DNB addresses the submitted responses in aggregate. In principle, DNB will also publish the content of the received consultation responses on its website, including the name of the organization where applicable. If respondents have explicitly granted permission, DNB will publish the consultation responses including the name and/or position of the respondent. 

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