Consultation reciprocation German macroprudential systemic risk buffer
The European Systemic Risk Board (ESRB) previously recommended reciprocating a macroprudential measure introduced by the German financial supervisory authority (BaFin), which DNB subsequently implemented. As of 1 May 2025, BaFin has reduced the systemic risk buffer to 1%. The ESRB has recommended acknowledging this revised buffer and applying it 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 1% systemic risk buffer, applied on an individual, sub-consolidated, and consolidated basis to all exposures (both retail and non-retail) related to natural and legal persons, secured by non-commercial real estate located in Germany. This measure applies to credit institutions using the Internal Ratings-Based (IRB) approach for calculating exposures secured by non-commercial real estate in Germany and credit institutions using the Standardised Approach (SA) for calculating risk-weighted exposures fully secured by non-commercial real estate in Germany.
Applicability
Due to reciprocity, this measure applies to the relevant exposures of subsidiaries and branches of Dutch credit institutions in Germany, as well as to relevant cross-border exposures of Dutch credit institutions related to Germany. An institution-specific threshold of EUR 10 billion applies. The measure becomes binding once the relevant exposures of credit institutions exceed this threshold. The German 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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