European Central Bank Proposes Easing Oversight of Small Banks: SNCI Threshold Could Rise to EUR 10 Billion
Impact level
⚪ Background
What happened
On October 7, 2026, the European Central Bank published a proposal in a supervisory blog post: national supervisory authorities could raise the total assets threshold for small and non-complex institutions (SNCIs) from EUR 5 billion to a maximum of EUR 10 billion. SNCIs could rise from 75% of less significant institutions (more than 1,400 as of December 2025) to 85%, adding around 150 banks. For some banks, SREP could take place once every two to three years, and bottom-up stress testing could become selective. A new SNCI category would be introduced in FINREP from 2027, following an initial public consultation; the number of reported data points could fall from around 13,500 to around 700. [1]
Seller impact
- FactThe proposal is at the preparation and implementation stage for measures within the ECB’s own remit. Measures beyond the ECB’s remit will need to be advanced with institutions such as the EBA. Neither the higher threshold nor the new FINREP category has been finalized; the scope and implementation timeline are unknown, and this does not represent a change to current compliance obligations. [1]
- InferenceInference: If more small banks are classified as SNCIs, reducing the frequency of SREP reviews and reporting volumes, constraints on credit supply to European SMEs could ease at the margin. However, the ECB has not announced whether individual countries will raise the threshold, and there are no data on loan pricing or credit volumes, so the actual impact on seller financing and consumer demand cannot be quantified. [1]
Suggested action
Monitor the ECB and EBA’s subsequent formal rule texts and the public consultation on FINREP; do not adjust any business arrangements on this basis for now.
Evidence that would disprove the assessment
- Assessment 1:This assessment should be updated if the ECB or EBA later announces that it has withdrawn or changed the threshold or the FINREP timetable.
- Assessment 2:This inference would no longer hold if national competent authorities announce that they will retain the EUR 5 billion threshold, or if SME loan rates and credit growth remain unchanged.