Buffers for systemically important banks: G-SII & O-SII

What are G-SII & O-SII buffers?

The capital buffers for globally systemically important institutions (G-SII) and other systemically important institutions (O-SII) are imposed on banks that are systemically important. Material problems with one of these institutions can have a disruptive impact on the stability of the financial system. The difference between the G-SII and O-SII buffer is the level at which a bank is considered systemically important:

• The G-SII buffers apply to banks (or banking groups) that are important in the international financial system.
• The O-SII buffers apply to banks (or banking groups) that are domestic systemically important.

Some institutions fall into both categories. In this case, only the higher of the two buffers applies. In the Netherlands, DNB is the designated authority for setting the G-SII and O-SII buffers. Since in practice the O-SII buffer is the higher of the two and therefore binding, the remainder of this factsheet focuses on the O-SII buffers. Afterwards, the results of last year’s G-SII assessment are briefly discussed.

How does DNB identify which institutions are an O-SII and subject to an O-SII buffer?

DNB identifies systemically important banks (or banking groups) based on the guidelines of the European Banking Authority (EBA). The identification consists of two steps: i) scoring based on the EBA methodology and ii) supervisory assessment by DNB.

1)    Scoring based on the EBA methodology

All Dutch banks and banking groups are assessed on ten indicators, divided into four categories: size, importance, complexity and interconnectedness (see the table below). Each of these four categories carries an equal weight of 25%. In total, 10,000 points are allocated. This results in a bank-specific score, the EBA score which reflects the relative domestic systemic importance. Banks with a score of at least 350 basis points are automatically designated as O-SII.

2)    Supervisory assessment by DNB

DNB can designate banks and banking groups with a score below 350 as O-SII based on a list of optional indicators, provided this is well substantiated. In doing so, DNB primarily considers two indicators:

• Number of deposit accounts. The impact of problems in banks with many retail clients would be relatively high because it could disrupt the access of many depositors to their funds.
• Deposits guaranteed under national deposit guarantee system (DGS). When a bank fails, depositors will be repaid up to €100,000 via the DGS. Other domestic banks contribute to these costs via the DGS fund, which can lead to financial pressure and contagion risk. This justifies maintaining an additional buffer for the bank concerned. 

How does DNB determine the buffer requirements?

The level of the O-SII buffers can be derived from the table below, in which DNB has translated the EBA scores into buffer levels.

Which banks and banking groups are designated as O-SIIs and have a buffer requirement?

In 2025, the same banks (or banking groups) as last year have been designated as O-SII in the Netherlands. ING, ABN AMRO, Rabobank and BNG are designated as O-SII due to their score above 350 basis points. In addition, ASN is designated as O-SII because of its relatively large share in the DGS. The table below shows the scores of the five O-SII in 2025 and 2024.

Based on the aforementioned method, the scores are translated into buffer requirements. These buffers must be maintained based on the highest consolidated financial position of the respective bank or banking groups. For all relevant banks and banking groups except Rabobank the buffer requirements remain unchanged. This is because the systemic importance of Rabobank compared to other banks in the Dutch banking sector has decreased. This lower score translates into a lower buffer requirement. The table below shows the buffer requirements as of December 2025 and the previous year. The next review of requirements is planned to take place in 2026. 

For which banks and banking groups is the G-SII buffer relevant?

In 2025, ING has again been identified as a G-SII. The G-SII buffer applicable to ING will not affect ING's risk-weighted capital requirement, as the O-SII buffer for ING is higher and the highest of these two buffers applies. The G-SII buffer requirement does have an impact insofar as it concerns the leverage ratio. ING needs to maintain an additional G-SII leverage ratio buffer, equal to half of the G-SII buffer, at 0,5%.

Every year, the Basel Committee on Banking Supervision (BCBS) and the Financial Stability Board (FSB) publish the methodology for identifying G-SIIs and the annual outcomes.