European Resolution Fund 2026: what changes in bank contributions

Key data

The annual contributions that banks and investment firms pay to the Single Resolution Fund (SRF) will be calculated differently from the entry into force of the Delegated Regulation (EU) 2026/440, published on 3 June 2026. The regulation modifies Delegated Regulation (EU) 2015/63, which until now fully regulated this process, and removes one of the risk indicators used to adjust individual contributions from each entity.

For CFOs and compliance officers of financial entities, this means that the quota your entity pays each year to the SRF may change, up or down, depending on what weight that eliminated indicator had in your particular risk profile.

What does this regulation establish?

Delegated Regulation (EU) 2015/63 establishes how ex ante contributions—that is, advance contributions, before any crisis occurs—to the Single Resolution Fund are calculated. This fund is the European mechanism that ensures that if a bank enters resolution, there are resources to manage it without resorting to public money.

The new Regulation (EU) 2026/440 introduces three blocks of changes to that base regulation:

The elimination of the risk indicator is the change with the greatest practical impact. Until now, each entity's contribution was not a flat fee: it was adjusted based on several indicators that measured its level of risk. By removing one of those indicators, the relative weight of the others changes, which alters the final calculation result for many entities.

Economic and operational impact

The specific economic impact of this modification varies depending on the risk profile and size of each entity, as the regulation itself acknowledges. There is no uniform effect: some entities will see their annual contribution to the SRF reduced and others will see it increased, depending on how the eliminated indicator weighed in their individual calculation.

From an operational perspective, the changes affect two levels:

• National resolution authorities: must adapt their calculation systems and internal procedures for determining quotas to the new methodology before the next settlement.
• Financial entities: must review how the new method affects their estimated contribution and update their projections of regulatory costs for the current fiscal year.

The procedural modifications introduced aim to simplify and expedite the quota determination process, which in practice can reduce the administrative burden associated with justifying and documenting the calculation.

Who does it affect?

• Credit institutions subject to the Bank Recovery and Resolution Directive (BRRD) and the Single Resolution Fund mechanism
• Banks with activity in the European Union required to make ex ante contributions to the SRF
• Investment firms included in the scope of Delegated Regulation (EU) 2015/63
• National resolution authorities responsible for calculating and communicating individual contributions to each entity
• CFOs, financial directors and regulatory compliance officers of financial entities that manage regulatory cost planning

Practical example

Imagine a medium-sized Spanish bank subject to the SRF whose annual contribution was calculated under Regulation (EU) 2015/63 with five risk indicators. One of those indicators—the one now being eliminated—penalized entities with a certain liability structure or level of exposure, increasing their risk-adjusted quota.

With the entry into force of Regulation (EU) 2026/440, that indicator disappears from the calculation. If that bank had a high-risk profile in that particular indicator, its adjusted contribution to the SRF could be reduced, since the factor that increased it is no longer applied. Conversely, an entity whose risk profile was favorable in that indicator—and which therefore benefited from a quota reduction thanks to it—could see its contribution increased as that downward adjustment disappears.

In both cases, the first step is for the financial team to request the national resolution authority to calculate the provisional amount under the new methodology to compare it with the amount from the previous fiscal year.

What should companies do now?

1. Identify if the entity is within the scope of application: confirm that the entity is subject to Delegated Regulation (EU) 2015/63 and, therefore, to the new Regulation (EU) 2026/440.
2. Review the current contribution calculation: analyze which risk indicators were applied in the last calculation cycle and determine which one is being eliminated, to estimate the impact on the quota.
3. Contact the national resolution authority: request information about the timeline for adapting to the new method and the estimated impact on the entity's contribution for the next fiscal year.
4. Update regulatory cost projections: review the compliance cost budget to reflect the possible change in the SRF contribution under the new methodology.
5. Adapt internal documentation procedures: take advantage of the procedural simplifications introduced by the regulation to reduce the administrative burden in the calculation justification process.
6. Monitor the entry into force date: given that it is not specified in the publication, remain alert to communications from the Single Resolution Board (SRB) and the national resolution authority about the application timeline.

Official source

Consult the complete regulation in the official source

Disclaimer: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://eur-lex.europa.eu/./legal-content/AUTO/?uri=CELEX:32026R0440