16th July 2026
Key takeaways
- The CMDI is a significant initiative that aims to address well-documented flaws in the current EU resolution framework, particularly as regards the resolution of mid-sized banks.
- Funding arrangements for transfer strategies, while made more flexible, are subject to conceptual limitations, technical ambiguities and a burdensome conditionality.
- The new legislation does not sufficiently correct the counterintuitive asymmetry between resolution and insolvency in terms of available funding.
- The CMDI does not envisage a recalibration of MREL on the basis of changed funding arrangements.
- Further reforms would be required for the banking union to meet its foundational objectives and minimise unintended effects on the competitiveness of the European banking industry.
1. Introduction
The European banking union was developed in the aftermath of the European debt crisis, which started in 2010, with two clear objectives: to break the sovereign-bank risk nexus that threatened the very continuation of the European Economic and Monetary Union and to help integrate the European banking industry. The regime for bank failure management is an essential element of that project. The Single Resolution Mechanism (SRM), which came into operation in 2015, is a pillar of the banking union alongside the Single Supervisory Mechanism and the, still pending, European Deposit Guarantee Scheme (EDIS). The SRM and EDIS were designed to contribute to denationalising banks’ risk through a common European framework for managing bank failures without domestic taxpayers bearing the cost.
It is now widely accepted that the banking union project has not been fully effective in delivering those objectives. There has been little progress in integrating the European banking industry since the creation of the banking union and use of resolution under the SRM has been inconsistent. The measures adopted in response to the failure of two significant Venetian banks – Banca Popolare di Vicenza and Veneto Banca – in 2017 demonstrated that crisis management may still require recourse to public financial support under a domestic regime. Moreover, the banking union resolution framework does not fully centralise resolution actions in the Single Resolution Board (SRB) and coexists with unharmonised national insolvency arrangements, which has an impact on aspects of resolution. As a result, the SRM has become a complex and inefficient policy set-up where different European and national rules and authorities interact and banks are subject to cumbersome and stringent obligations, including the minimum requirements for own funds and eligible liabilities (MREL) (Restoy and Walters (2026)).
In April 2026, after three years of discussion, the European co-legislators approved a package that reformed aspects of the framework for crisis management and deposit insurance. Known as the CMDI, the package amends the Bank Recovery and Resolution Directive (BRRD), the Single Resolution Mechanism Regulation (SRMR) and the Deposit Guarantee Scheme Directive (DGSD).2 The reforms have two broad objectives, both inspired by the episode of the failing Venetian banks. The first is to increase the scope for resolution action to be taken under the European resolution framework rather than national insolvency regimes. The second is to facilitate the provision of external funding for the resolution of failing mid-sized institutions.3
Those objectives, while necessary, arguably do not mitigate the main factors that give rise to the most significant flaws in the existing framework.4 The CMDI does nothing to reduce its complexity. Moreover, because EDIS is not part of the package, it is unlikely to advance the denationalisation of banks’ risk. Nevertheless, the CMDI is likely to be impactful since those stated objectives address material shortcomings that have impaired the SRM’s ability to operate effectively since its creation.
This article offers a brief assessment of the CMDI against its objectives. Section 2 discusses the main elements of the legislative package. Section 3 assesses the changes to the scope of application of resolution relative to insolvency and to the funding of resolution actions. Section 4 concludes.
2. What the CMDI brings
The CMDI package contains a range of technical improvements to aspects of the crisis management framework. They encompass actions prior to resolution, resolution preparation and execution and crisis management outside of resolution. As regards actions prior to resolution, the amendments clarify the scope and the nature of supervisory early intervention measures and ensure that the SRB has access to all supervisory information that it needs to perform its functions properly. The package also specifies conditions for the recognition of non-covered deposits to meet MREL, introduces minimum MREL levels for banks with a preferred transfer strategy (using a sale of business or bridge bank) and establishes conditions for the treatment of contingent liabilities when bail-in powers are used. As regards crisis management outside of resolution, the CMDI codifies the conditions for provision of extraordinary financial support that entails state-aid. It also clarifies the interaction between support actions to be taken by institutional protection schemes and resolution measures. Those changes improve clarity and should support necessary notifications and information sharing in the run-up to an expected resolution.
However, the most substantive aspects of the reform package relate to its principal objectives of ensuring that all bank failures with systemic implications are dealt with under the resolution framework and making external funding available to support transfer-based resolutions of medium-sized banks that entail their market exit. These objectives are linked. The 2017 cases of the Venetian banks were notable because, despite their provision of critical functions in the region where they operated, the failing banks were managed through national insolvency measures that included the use of public funds, rather than being resolved under the SRM.
Accordingly, the CMDI amendments aim to remove ambiguity in the conditions that determine whether a failing bank is managed under the European resolution framework or national insolvency regimes. This is intended to ensure that resolution is used in all bank failures that could have systemic implications. Connected to that goal, the CMDI also aims to address reasons why authorities might resort to national insolvency procedures to manage failures of significant banks. Those reasons reside in the greater flexibility that member States have to use public funds to preserve financial stability when a bank is subject to an insolvency procedure than exists in resolution. The anomaly here is clear: public support is more readily available in liquidation, which should be used for non-systemic failures, than for resolution, which is the intended procedure for bank failures that could have implications for financial stability.5
The CMDI pursues these objectives through two sets of changes. First, it lowers the bar for a bank failure to be considered systemic (the public interest assessment (PIA)). A positive PIA is a necessary condition for the use of resolution rather than insolvency. Second, it facilitates financial support by deposit guarantee schemes (DGS) and resolution funding arrangements for transfer transactions in resolution.
Changes to the public interest assessment
The CMDI does not substantially modify the definition of public interest as a threshold for resolution. The definition is linked to the statutory objectives of resolution, which are to ensure continuity of critical functions, avoid significant adverse effects on financial stability, protect public funds, and safeguard deposits and clients’ assets.6 However, it does clarify the PIA in three respects. First, it specifies that a positive PIA should be possible where a bank failure entails the risk of “discontinuity of critical functions” or “adverse effects of financial stability” at a regional level, and not only at the level of the national or EU economy.7 Second, when conducting a PIA, resolution authorities will be required to compare any extraordinary public financial support that could reasonably be expected to be provided if the bank were liquidated with that expected if it were resolved. A recital8 indicates that funding from industry-funded arrangements such as a DGS or a resolution fund should be preferred to an equal amount provided directly by governments (under insolvency). This is reinforced by an amendment to the resolution objectives to specify that the objective of minimising reliance on public financial support applies particularly when it is provided from the budget of a member State.9 Third, the definition of when resolution is necessary in the public interest is amended to state that, where one or more of the statutory resolution objectives would be at risk if a bank were wound up, the PIA should only be negative if it is proved that an insolvency procedure would achieve those objectives more effectively than resolution.
Changes to DGS funding for transfer-based resolution
More potentially impactful are the changes related to the objective of improving funding for transfer strategies. This is achieved by amendments to the provisions on the contribution that a national DGS may make to fund a transfer-based resolution and on access to the SRF. The amendments focus on small and medium-sized banks, for which transfer strategies are typically adopted and which are most likely to be funded primarily by deposits.
Since its inception, the EU resolution framework has required the DGS to contribute funds to a resolution that ensures that depositors continue to have access to their deposits. To date, that contribution has been calculated by reference to the amount of losses that covered deposits would suffer if they had been exposed to loss in resolution and capped at the cost that the DGS would have borne in a (counterfactual) liquidation. That cap is quantified as the difference between cost to the DGS of paying out the covered deposits and the recoveries it would have received in the liquidation of the failing bank, in accordance with its creditor ranking in the applicable national insolvency procedures.10 Since EU legislation gives DGS claims a high priority (ranking above non-covered deposits and senior debt instruments), expected net losses for the DGS in liquidation are typically small, meaning that the available support from the DGS is often almost negligible.
The CMDI modifies how the DGS contribution is calculated where the resolution is based on a transfer transaction. Under the new rules, it is calibrated as an amount necessary to cover the difference between the value of transferred assets on the one hand and the transferred deposits and other liabilities of the same or higher ranking in insolvency, on the other.11 That amount is subject to two limits: i) the total volume of covered deposits, which replaces the ‘least cost’ cap based on the net cost of payout of covered deposits; and ii) 62.5% of target level of DGS, unless waived for reasons of financial stability.12 Taken together with the new approach to calibrating the DGS contribution, the revised limits should, in principle, be less restrictive than the current cap based on the net cost of payout.
The second potentially impactful change allows the DGS contribution to facilitate use of resolution funding arrangements (the SRF or national resolution fund, as applicable)13 in some bank resolutions based primarily on transfer tools. This is informally referred to as the “DGS bridge”. Use of SRF in a resolution is conditional on the prior bail-in of at least 8% a bank’s total liabilities and own funds (TLOF). The DGS contribution to a transfer-based resolution may count towards that requirement if the following conditions are met: (i) the failing bank’s balance sheet does not exceed EUR 80bn; (ii) the bank has not been earmarked for liquidation in a resolution plan in the preceding 24 months (meaning that its MREL requirement includes a recapitalisation amount); and (iii) all the bank’s own funds and eligible liabilities have been written down or converted (unless legitimately excluded from bail-in). An additional condition applies for banks with more than EUR 30bn in assets. The DGS bridge may only be used if such a bank is subject to an MREL requirement that is at least equal to the new minimum of 16% of RWA or 4.75% of total exposure measure (TEM) that the CMDI introduces for banks with a transfer-based resolution strategy.14 Moreover, for such banks, the DGS contribution that facilitates access to the SRF may not exceed 2.5% of the bank’s TLOF. Finally, member States may also limit the DGS bridge to banks that have consistently complied with MREL.15
Where these conditions are met, financial support from both DGS and SRF could be available for mid-sized banks with a transfer-based strategy. In such situations, the latter is the primary source of funding and the DGS contribution is capped at the amount needed to meet the 8% minimum bail-in threshold, taken together with the previous contribution from shareholders and creditors.
3. Assessment
Resolution versus insolvency
The CMDI does not fundamentally alter the structure of the PIA. Within that framework, however, it provides guidance on the factors in that assessment. Substantively, it moderately raises the threshold for using national insolvency procedures rather than resolution. The intention is clearly that any bank failure in which objectives such as financial stability, depositor protection or minimising reliance on public financial support are in play should be managed under the resolution framework, unless winding up would produce better outcomes in respect of those objectives. The reforms to the DGS contribution support that aim by improving the feasibility of resolution for small and mid-sized banks.
However, it appears to remain possible for national authorities to use insolvency (and associated public support) if - despite the new provisions relating to the DGS contribution – the funding available in resolution is not enough to preserve financial stability. This is because the CMDI retains the anomaly whereby external support may be more readily available for failures that are dealt with under an insolvency framework (which should be less systemic) than those that are managed through resolution (the procedure designed for systemic bank failures).
In resolution, DGS and SRF funding is capped, 16 access to the SRF remains conditional on the prior loss absorbency of at least 8% TLOF, and provision for the DGS contribution to count towards that 8% is limited to banks with total assets under EUR 80bn. By contrast, public funding may still be used as liquidation aid in an insolvency procedure,17 as it was in the case of the Venetian banks. The principal constraint is the State aid framework.
The option of using insolvency in a case where resolution objectives are engaged remains open because of the way the PIA is framed. If more funding would be available in insolvency than in resolution, the resolution authority might legitimately determine that insolvency would produce better outcomes as regards financial stability. This would, of course, need to be weighed against the objective of protecting public funds by minimising reliance on extraordinary public financial support, but the outcome of that would not necessarily lead to a decision for resolution in all cases. This situation illustrates a tension that is common to resolution frameworks between the objectives of maintaining financial stability and protecting public funds.
DGS support for transfer strategies
The CMDI includes helpful provisions that should increase the DGS contribution to transfer-based resolutions. However, by replacing the cap based on the net cost to the DGS in a liquidation, coupled with provision for the DGS contribution to protect uninsured deposits and other equally or higher-ranking liabilities in specific circumstances, the reforms result in an implicit change to the DGS mandate, beyond protection of covered deposits.18 That extension overlaps with the systemic remit of resolution funds and could result in higher costs to the DGS in resolution than in a payout liquidation.
While the DGS contribution in resolution cannot exceed the total amount of covered deposits in a bank, in practice the binding limit on the amount available might be the calibration of the contribution as the difference between the value of transferred deposits (and other relevant liabilities) and of transferred assets. There is ambiguity in this regard since the method to be used to value the assets is not specified. That method is crucial because different valuation approaches would produce different outcomes. A valuation based on economic or accounting values is likely to result in an amount that is too low to bridge the funding gap that DGS support would need to fill. By contrast, a valuation derived from the offer(s) submitted by the bidder(s) would allow the DGS contribution to meet the funding needs (subject to the caps), although in this case the provision about calibration would be largely redundant.
Arguably, the European Commission’s original proposal for the CMDI would have provided a more effective (and well-tested) formula for addressing those issues. That proposal would have replaced the current super-preference of insured deposits by a single tier general depositor preference,19 while maintaining the current cap on the DGS contribution (cost of paying out covered deposits net of recoveries in the liquidation counterfactual). This would have removed the ambiguity about valuation, implied no change in the mandate of the DGS and ensured that cost for the DGS in resolution would not exceed that in a payout liquidation.
SRF support
The idea of facilitating use of the SRF to support transfer transactions is a clear improvement that should alleviate obstacles to the resolution of small and mid-sized banks. However, the provision is restricted to banks with less than EUR 80 bn in total assets. This threshold, which was not included in the original Commission proposal, appears somewhat arbitrary and could limit its potential utility. Banks with assets over EUR 80bn might be suitable for a transfer-based resolution strategy and hold non-deposit liabilities that would, ideally, be transferred to an acquirer and may be attractive to bidders. However, in some cases, the combination of MREL and the DGS contribution may not be sufficient to support of transfer of liabilities that includes a large amount of non-deposit liabilities (some of which may be junior to deposits).20 For banks above the EUR 80bn asset threshold, the DGS contribution could not count towards meeting the conditions for SRF access, and supplementary SRF support might not therefore be available.
The rationale for the threshold is, presumably, that larger banks can be expected to maintain sufficient MREL for this purpose.21 But there may be instances – for example, where a large part of MREL is met with equity which may have diminished significantly prior to a resolution - where that is not the case. It appears somewhat contradictory that an arbitrary threshold could prevent SRF resources from being available precisely for larger banks, whose failure is likely to be more systemic.
On MREL
By increasing the DGS contribution, the CMDI should help make transfer-based strategies a credible alternative to open bank bail-in for banks where suitable purchasers are available. However, a key question remains: how much MREL should banks with a sale of business resolution strategy be required to maintain? Under the current MREL framework that was introduced in 2019,22 the SRB may adjust MREL for banks with a partial transfer strategy in recognition of the lower recapitalisation needs for the business to be maintained. The recapitalisation amount (RCA) of MREL may be reduced by applying a scaling factor of between 15% and 25% to the total assets and calculating it on that basis. Within that corridor, the SRB decides the factor in a specific case based on considerations designed to capture the marketability and capital needs of the resolved entity.23 That discretion remains unchanged by the CMDI.
Neither the current framework nor the CMDI revisions explicitly permits MREL to be reduced to reflect the expected amount of the DGS contribution to a transfer-based resolution. Since the framework details with some precision the upwards and downwards adjustments to MREL that may be made on an institution-specific basis, an implicit authority to reduce MREL to take account of expected DGS funding cannot be inferred. Based on this understanding, the CMDI does not contemplate a material reduction in MREL requirements for banks with a transfer strategy, even if more external funding is likely to be available from a larger DGS contribution. Indeed, the CMDI establishes an MREL floor for banks with total assets between EUR 30bn and 80bn.
It is clear that MREL remains the first line of defence in failure management for mid-sized banks. This is consistent with the objective of the resolution framework to minimise the risk of loss to public funds. However, there is a disconnect between the MREL requirements and the support from industry-funded sources that would be available in resolution. This contrasts with the changes to the UK resolution framework adopted in 2025 that combine a new mechanism by which the Financial Services Compensation Scheme can provide funds to support small bank resolution using transfer powers with reductions in MREL for banks with a preferred resolution strategy (PRS) based on transfer.24
4. Conclusions
The CMDI is a significant initiative that aims to address well-documented flaws in the EU resolution framework such as the boundary between the European resolution framework and national insolvency regimes and the risk of insufficient funding for the resolution of mid-sized banks. The provisions discussed are a step in the right direction. Nevertheless, certain technical limitations prevent the new legislation from fully meeting its stated objectives.
The relative scopes of resolution and insolvency are still insufficiently delimited and the modifications retain the counterintuitive asymmetry in the extent to which external funding – in particular, extraordinary public funding – is available under each regime. This, in turn, keeps in place the reasons why authorities might use insolvency procedures rather than resolution, despite the intention to expand the scope of resolution through the changes to the PIA.
As a point of principle, by extending the potential funding remit of DGS in certain transfers that include uninsured deposits and other liabilities - even if that is more costly for the DGS than paying out covered deposits in liquidation - the CMDI blurs the line between the roles of DGS and resolution funds. On the technical level, although the reforms facilitate funding for transfer strategies from national DGS and the SRF, the impact in practice will depend on how transferred assets are valued for the purposes of determining the amount of the DGS contribution. Moreover, while the ‘DGS bridge’ facilitates access to SRF funds for transfer-based resolutions, the arrangement depends on complex conditions being met and is not available in circumstances where the remaining loss absorbing capacity of a larger bank in resolution is insufficient to deliver the required write down of 8% TLOF. Finally, it is somewhat odd that a significant reform of the external funding arrangements for resolution transfers is not reflected in MREL calibration, particularly since a rationale for the reform was the challenges that some small and mid-sized banks have experienced in issuing bail-inable liabilities.
While the impact of CMDI should be net-positive for the European financial system, this package is not (and does not attempt to be) the comprehensive reform that is needed for the banking union to meet its foundational objectives while minimising unintended effects on the competitiveness of the European banking industry. Further initiatives are expected following the Commission’s recent targeted consultation on the competitiveness of the EU banking sector. This should be an opportunity to make tangible progress towards denationalising banks’ risk and ensuring that sufficient funding will be available for the resolution of any systemic European bank.
Author's note
- Financial Stability Institute of the Bank for International Settlements (BIS). Views expressed are our own and not necessarily those of the BIS or its member institutions.
Endnotes
- The CMDI package consists of Directive (EU) 2026/806, which amends Directive 2014/59/EU (BRRD); Regulation (EU) 2026/808, which amends Regulation (EU) No 806/2014 (the SRMR); and Direction (EU) 2026/804, which amends Directive 2014/49/EU (DGSD). For background on the package, see Berrigan (2023). See Laboureix (2025) for reflections on the expected impact of the CMDI.
- The issue of mid-sized institutions is recognised explicitly in the recitals of the CMDI. See, for example, recital (2) of Directive (EU) 2026/806: “it is therefore necessary to ensure a more effective and coherent application of the Union resolution framework and to ensure that it can also be applied whenever doing so is in the public interest, including for certain smaller and medium-sized institutions which are primarily funded through deposits and do not have sufficient other bail-inable liabilities.” It is discussed in Restoy (2018), Restoy et al (2020) and SRB (2024b). See also Biraschi et al (2023) for an analysis of the original proposal of the European Commission.
- Those flaws, which include cumbersome decision-making procedures, detailed arrangements for coordination among authorities, granular and complex regulation and a complicated interaction with national insolvency regimes, result from institutional singularities of the EU and banking union frameworks. See Restoy and Walters (2026), Gelpern and Véron (2019) (for a comparison with the US framework) and Dombret (2019).
- The existence of less stringent rules on access to funding outside resolution, and the impact on the use of the EU resolution framework in favour of national insolvency measures, is noted in the CMDI recitals (eg, See, for example, recital (2) of Directive (EU) 2026/806).
- BRRD Article 32(1)(c) and (5), read with Article 31.
- This is specified in recital (11) of Directive (EU) 2026/806), amending the BRRD, and is reflected in the amendment to the definition of “critical function” in Article 2(1) of the Directive.
- Recital (13) of Directive (EU) 2026/806) and recital (19) of Regulation (EU) 2026/808, which amends the SRMR
- See the amendments to point (c) of BRRD Article 31(2) and SRMR Article 14(2).
- This is a “least cost” provision that aims to ensure that the DGS will not incur higher costs in a resolution through its required contribution than it would in a liquidation and payout of covered deposits. The way that the “least cost” cap is calculated has been interpreted differently across member States, leading to divergent outcomes. The CMDI has aimed to achieve greater harmonisation in this respect.
- In the baseline case, the amount is calculated using the value of the bank’s covered deposits and liabilities that rank equal to or higher than covered deposits). However, where the transfer perimeter includes non-covered deposits or other bail-in-able liabilities, the amount of the DGS contribution may be adjusted to the difference between the value of (i) the deposits and other liabilities of the same or higher ranking than covered deposits in insolvency and (ii) the assets, to be transferred. This is possible subject to two conditions: the resolution authority determines that those liabilities should be excluded from bail-in on one of the grounds permitted (eg, such exclusion is necessary to achieve continuity of critical functions or to avoid widespread contagion), and it is not possible to achieve the write down of 8% of total liabilities and own funds that is required to access the SRF. In all cases, the DGS contribution can include an additional amount to ensure capital neutrality for the acquirer.
- The limit of 62.5% of the fund target level may be exceeded if a higher contribution is necessary to avoid adverse effects on financial stability or preserve depositors’ access to their deposits.
- “Resolution funding arrangements” refers to the SRF or national resolution funds, depending on whether a failure falls within the SRM. In the interests of brevity, this note will refer only to the SRF but, where applicable, the DGS bridge also facilitates use of national resolution funds.
- It may still be possible for the DSG contribution to facilitate access to the SRF if, at the point of failure, a bank’s MREL has fallen beneath that minimum, provided that its MREL had been set as at least the specified minimum and it had consistently complied with that requirement. Under the BRRD, the equivalent minimum MREL is 15% of RWA or 4.5% of TEM.
- In this event, a bank must not have breached its MREL requirements for two consecutive quarters over the 24 months preceding a three period before the resolution action. This condition is obligatory under the SRMR.
- The caps on the DGS contribution are discussed in section 2. The amount of SRF funds that may be used in a single resolution is capped at 5% of the TLOF of the bank in question.
- This is additional to the possibility, where implemented in national law, of using the DGS to fund ‘alternative measures’ in the context of a liquidation, such as a transfer that preserves access to deposits (Article 11(5) of the DGSD, as revised by the CMDI). Like the DGS contribution to resolution, DGS funding of alternative measures is capped at the total amount of covered deposits of the bank in question.
- This is reflected in CMDI amendment to Article 1 of the DGSD, which states the purposes of the directive. The revised version refers to non-payout measures that ensure the access of depositors to their deposits – a formulation that is not limited to covered deposits.
- Under which insured deposits would rank equally with uninsured deposits and, as a class, higher than other non-preferred unsecured liabilities.
- The DGS contribution may help fund a transfer that includes liabilities junior to covered deposits. However, the amount of the contribution is calibrated as the difference between the value of transferred assets and transferred deposits and equally or higher-ranking liabilities. Other liabilities ranking junior to covered deposits are not used to calculate this difference. This means that the DGS does not contribute to funding their transfer and another source of funding (such as the SRF) would need to be used.
- The MREL framework provides that SRB may raise a bank’s leverage-based MREL amount up to 8% of TLOF if considers it necessary to ensure that the bank has sufficient MREL to meet the bail-in required for use of SRF resources. Banks in resolution groups with a consolidated balance sheet above EUR 100 bn (Pillar 1 banks) must maintain subordinated MREL resources equal to at least 8% of the TLOF to ensure that the conditions for access to the SRF can be met.
- Amendments introduced by BRRD 2 (Directive (EU) 2019/879 amending Directive 2014/59/EU as regards the loss-absorbing and recapitalisation capacity) and parallel amendments to the SRMR introduced by Regulation (EU) 2019/877.
- These are the size of the bank, the proportion of impaired assets on its balance sheet, the nature of its depositor base, levels of uncertainty in valuation that may affect marketability and an assessment of its progress towards resolvability (SRB 2024a).
- The funding mechanism is established by the Bank Resolution (Recapitalisation) Act 2025 This alternative source of funding makes it possible to reduce to zero the recapitalisation component of MREL for the small number of UK banks with a transfer PRS. See BoE 2025.
References
Bank of England (BoE) (2025): Statement of policy: The Bank of England’s approach to setting a minimum requirement for own funds and eligible liabilities (MREL), July.
Berrigan, J (2023): Speech at the SRB/SSM seminar on crisis management and deposit insurance (CMDI), Brussels, October.
Biraschi, P, R de Bosio, M Langella, B Mainieri, N Mata Garcia and L Orszaghova (2023):"The Commission proposal to reform the EU Bank Crisis Management Framework: A selected analysis", SRB Working Paper Series #3, December.
Dombret, A (2019): “A brief progress report on the resolution framework in Europe”, in A Dombret and P Kenadjian (eds), Resolution in Europe: The Unresolved Questions, De Gruyter, 2019.
Gelpern, A and N Véron (2019): "An effective regime for non-viable banks: US experience and considerations for EU reform", Study requested by the ECON committee, July.
Laboureix, D (2025): "Unlocking the potential of CMDI reforms", Speech at the IADI – Europe Regional Committee Conference, October.
Restoy, F (2018): “Bail-in in the new bank resolution framework: is there an issue with the middle class?”, March, speech at the IADI-ERC International Conference: “Resolution and deposit guarantee schemes in Europe: incomplete processes and uncertain outcomes”, Naples, March.
Restoy, F, R Vrbaski and R Walters (2020): “Bank failure management in the European banking union: What’s wrong and how to fix it”, FSI Occasional Papers no 15, July.
Restoy, F and R Walters (2026): “What needs to be done to improve the efficiency of the resolution framework of the banking union", FSI Occasional Papers no 26, March.
Single Resolution Board (SRB) (2024a): Minimum requirement for own funds and eligible liabilities (MREL), May.
Single Resolution Board (SRB) (2024b): Small and medium-sized banks: resolution planning and crisis management for less significant institutions in 2023 and 2024, September.
Fernando Restoy became Chair of the Financial Stability Institute, Bank for International Settlements (BIS) in January 2017.
He had been Deputy Governor of the Bank of Spain since 2012. Since 1991, he held other senior positions at the Bank of Spain. From 1995–97 he was Economic Advisor and Head of the Monetary Framework Section at the European Monetary Institute. He was Vice Chair of the Spanish Securities and Markets Commission from 2008–12 and Vice Chair of IOSCO Technical Committee. He was the Chairman of the Spanish Executive Resolution Authority from 2012–15 and has been a Member of the Supervisory Board of the ECB-SSM from 2014–16.
He holds an MSc in econometrics and mathematical economics from the London School of Economics and an MA and PhD in economics from Harvard.
Rastko Vrbaski is the Senior Adviser of the Financial Stability Institute, Bank for International Settlements (BIS). Rastko joined the FSI in September 2019. He works on policy analysis and contributes to training activities and the FSI outreach programme. Prior to joining the FSI, Rastko was a senior manager in the resolution directorate of FINMA, the Swiss financial market supervisory and resolution authority, having previously worked in bank supervision and as an attorney in private law firms. Rastko is a German-qualified lawyer and holds a doctoral degree in law from the University of Tuebingen, Germany (2005).
Ruth Walters is the Senior Adviser of Financial Stability Institute, Bank for International Settlements (BIS). Ruth has worked at the FSI since 2018. She contributes to its publications and its training and outreach activities, including the organisation of cross-border crisis simulation exercises. Prior to joining the FSI, she was a senior manager in the Resolution Directorate at the Bank of England. She has also worked on resolution regimes at the FSB Secretariat, and on resolution, the capital framework and market regulation at the European Commission. Ruth is a UK-qualified lawyer, specialised in regulatory law, and has practised law both in the UK government legal service and in a law firm.