EBA publishes no-action letter and technical guidance for EU bank market risk framework

The European Banking Authority (EBA) has published a no-action letter regarding the boundary between the banking book and the trading book. It also shared technical clarifications related to the European Commission’s Delegated Act that modifies the calculation of own funds requirements for market risk based on the Fundamental Review of the Trading Book (FRTB) framework.

The measures aim to ensure a consistent and harmonised implementation of the revised framework across the European Union (EU). The Delegated Act is currently under review by the European Parliament and the Council. The EBA’s guidance will become relevant once the Delegated Act enters into force.

In its no-action letter, the EBA recommends that competent authorities do not prioritize supervisory or enforcement actions concerning the boundary between the banking and trading books, internal risk transfers, and related reporting requirements. This guidance is intended to prevent operational complexity and level-playing-field concerns among institutions, especially those applying the institution-specific multiplier introduced by the Delegated Act.

The EBA also provides technical considerations on key implementation issues for the application of the market risk framework as amended by the Delegated Act. Additionally, the EBA clarifies the treatment of institutions for supervisory benchmarking purposes.

The no-action letter is issued under Article 9c of Regulation (EU) No 1093/2010 (EBA Founding Regulation). The Delegated Act, adopted on 4 June 2026, under Article 461a of Regulation (EU) No 575/2013 (CRR), will modify the calculation of own funds requirements for market risk from 1 January 2027 for three years. It includes targeted adjustments to the FRTB framework and related guidance to facilitate consistent implementation across the EU.