SRB interview: operational implementation of resolvability

The SRB recently published two important documents clarifying its expectations of banks regarding operational resolvability: the Operational guidance for banks on resolvability self-assessment (August 2025) and the Operational guidance on resolvability testing for banks (September 2025). These texts implement the SRM Vision 2028 and mark the transition from planning to execution. The first introduces a harmonised self-assessment format, to be submitted every two years (first due date: 31 January  2026), while the second defines the operational framework of the Multi-Annual Testing Programme (MATP) which structures resolvability tests carried out jointly by banks and their Internal Resolution Teams (IRTs). 

In this exclusive interview with Forvis Mazars, Mr. Dominique Laboureix outlines the SRB’s expectations in this area and the elements banks must consider in their preparation. 

Start of SRB transcript: 

Interview with Dominique Laboureix on the operational implementation of resolvability  

 
Interview with Dominique Laboureix, Chair of the Single Resolution Board (SRB), by Eric Cloutier, Global Head of Banking Regulations at Forvis Mazars 

1. As the SRB moves from planning to execution under its Vision 2028, banks are now called upon to demonstrate their operational capacity to implement their resolution plans. The SRB seeks to verify not only the existence of resolvability capabilities, but also their effective implementation within the required timelines. The publication of the Operational Guidance on Resolvability Testing for Banks (Testing Guidance) marks a turning point in how resolvability will now be assessed in practice by the SRB. For context, could you please recall how the SRM Vision 2028 redefines the SRB’s expectations regarding the operational implementation of resolution plans? What role will these new guidances play in this transition from planning to execution? 

Answer of Mr. Laboureix: 

The SRM Vision 2028 aims to strengthen the operationalisation of resolution plans. This is why SRM Vision 2028 places banks’ operational capabilities — particularly resolvability testing — at the very core of its strategy. 

The two new operational guidances published last August and September contribute to this objective. Based on the European Banking Authority (EBA) guidelines, they provide a framework for banks to follow, consisting of: 

A harmonised approach for all banks to assess their ability to be resolvable. This approach is introduced through the operational guidance on resolvability self-assessment, which requires banks to evaluate their ability to implement regulatory requirements in a crisis. 

And, on the other hand: 

A methodology setting out the SRB’s expectations on testing, introduced through the operational guidance on resolvability testing. These tests are carried out by the banks themselves and are intended to verify their preparedness to face crisis situations and their readiness to take resolution actions. 

These two approaches — the self-assessment on the one hand and testing on the other — are complementary, as testing makes it possible to verify the capabilities declared by the bank in its self-assessment, while also generating insights into its resolvability at a more operational level. The bank will subsequently reflect these insights in the updated version of its self-assessment. 

Allow me to add that we have sought to provide as much clarity as possible to banks during the development process of these two guidances. We conducted extensive industry consultations on both guidance documents and organised open webinars during which our teams responded to all outstanding questions. 

I believe this exchange greatly contributed to the quality of these documents and to the banks’ understanding of our concrete expectations in terms of resolvability. 

2. With the introduction of the Operational Guidance for Banks on Resolvability Self-Assessment (Self-Assessment Guidance), banks must now articulate two complementary approaches: the self-assessment of their resolvability and its verification by the authorities. The SRB emphasises continuous interaction between these two components, aiming to establish a structured feedback loop. The results of resolvability tests should help adjust internal evaluations, while self-assessments guide verification priorities. Yet, many institutions are still seeking to translate this dynamic into their governance and internal processes. What does the SRB expect from banks, particularly in terms of organising their governance and internal planning, to ensure a coherent and practical implementation between the self-assessment of their resolvability and the operational tests planned by the SRB? 

Answer of Mr. Laboureix: 

We want the concept of resolvability to be clear for all banks. Put differently: what should be done when things go wrong? 

Let me also remind you that resolvability is a major component of a bank’s strength and resilience, and we understand that it comes at a cost. 

It must therefore be understood and supported at the highest levels of the bank’s governing bodies — that is, by senior management as well as the board of directors. But this awareness must also be shared by the teams responsible for resolution matters. Senior management must ensure this support and make the resources necessary to achieve progress in terms of resolvability available. 

You are right to emphasize the two components in our approach. Clearly, these components need to interact with each other and be embedded in the day-to-day operating model of the bank’s internal teams. 

First, we ask banks to assess their own resolvability. As a matter of fact, this self-assessment is not a new exercise for banks and their teams. They have been doing it since the early development of the resolvability capabilities defined in the Expectations for Banks. 

The standardised report introduced by the new operational guidance should enable all banks under the SRB’s remit to carry out their self-assessment in a more consistent manner. Of course, this report provides for certain adjustments to reflect different business models among banks and ensure a proportionate approach. 

Second, SRB teams and national resolution authorities (internal resolution teams, or IRTs) verify whether the capabilities are truly operational through a series of tests. When setting them, IRTs take banks’ resolvability assessment (including their self-assessment) into account. 

Resolvability testing is nothing unknown to banks either. Banks have already been testing their operational capabilities for several years, especially in relation to bail-in, liquidity and the valuation of their balance sheet. 

The new guidance builds on this experience and offers a more harmonised and systematic approach that covers all the resolvability dimensions of the Expectations for Banks’. 

Under this new approach, IRTs define a testing programme (the multi-annual testing programme, or MATP) that spans over a three-year period. These tests either cater to specific expectations set for a given bank or form part of common priorities for a group of banks with shared characteristics. 

All in all, this approach provides for a clearer and predictable process. It should enable banks to be in a better position to organise themselves ahead of the tests and allocate the necessary resources and budget. 

3. The SRB now expects banks to demonstrate the ability to implement resolution plans in a credible and operational manner. What does the SRB expect from banks to ensure realistic scenarios, effective internal coordination, and rigorous documentation? 

Answer of Mr. Laboureix: 

I would first like to reassure banks: for each test included in the MATP, the IRTs will take the time to explain their expectations to the banks. This is especially true for the more technical aspects such as the scenarios. 

These scenarios will be adapted for each bank to ensure their relevance to the bank’s specific characteristics. In all cases, the specific tests will be the result of discussions between the IRT and the bank ahead of their execution. 

During the execution of the test, the IRTs will not intervene — the idea is to preserve complete independence. However, the IRT may silently observe the course of the test and can provide feedback once the test is over. This ensures a clear separation between the test conducted by the bank and its subsequent assessment by the IRT. 

You also mentioned internal coordination. Banks are required to prepare an internal resolvability testing plan describing how they intend to implement the MATP. This plan must be approved by the member of the management body responsible for resolvability and be submitted to the IRT no later than 31 January of a given year. 

The bank’s internal resolution planning function then steers and implements the MATP. It also ensures that all the relevant internal functions contribute to the preparation and execution of the tests. 

It is therefore essential that this team has the necessary resources to manage these resolvability tests. 

4. Does the SRB expect banks to involve their internal audit or an independent function to validate their resolvability self-assessments? 

Answer of Mr. Laboureix: 

We do not expect internal audit or another independent function to validate the self-assessment, as we understand that the scope of the work is broad and may involve many departments. However, we expect the self-assessment report to be validated or signed by the member of the management body responsible for resolution. 

Regarding the execution of the tests, the SRB recommends that an independent observer be present during the tests. This role may be assigned to internal audit or another function whose independence is ensured. 

5. Resolvability tests mobilise a significant volume of critical data and exchanges between multiple internal systems. In the Testing Guidance, the SRB insists on the quality, consistency, and traceability of the information used, as well as on banks’ ability to reproduce test results. What are the SRB’s concrete expectations regarding data governance and information flow management in the context of resolvability tests, including the use of test environments distinct from production systems? 

Answer of Mr. Laboureix: 

Data governance and the management of information flows are essential elements for a successful resolution. At the end of the day, it is quite straightforward: if we do not have access to accurate and complete data, we will not be able to execute the resolution tool. 

This is why we place such a strong emphasis on data and management information systems (MIS) more broadly in our tests. 

Our operational guidance includes a series of tests designed to verify resolution capabilities related to management information systems. The objective is to ensure that governance processes and mechanisms are in place, that the MIS systems operate effectively in a resolution scenario and that the actions set out in procedural manuals or “playbooks” produce the expected results. 

Regarding the use of testing environments, it is not necessary to provide one for all tests. We have paid close attention to the feedback from the public consultation and have decided to limit their use. 

Testing environments are only required for certain tests relating to the operationalisation of bail-in. In this case, we consider that a simulation in a production environment would not be feasible, as it would disrupt the day-to-day functioning of the systems. 

As a rule, for the other tests, banks may use their normal production environments, provided that protective measures are in place to avoid or mitigate the risks associated with the tests. Naturally, when banks use these production environments for testing, they must check whether these environments can handle the additional workload linked to the resolution test and identify any potential bottlenecks. 

Lastly, when banks use a testing environment, they are required to specify the characteristics of that environment and put the necessary controls in place to ensure its proper functioning. Once the test is completed, the testing environment does not need to be permanently maintained or updated. 

6. Some institutions have raised concerns about the complexity and cost of resolvability tests, particularly for medium-sized banks or those adopting simplified resolution strategies. The principle of proportionality is clearly mentioned in both SRB guidances, but its concrete implementation remains a central issue. How does the SRB apply the principle of proportionality in practice, and how are expectations adapted to banking profiles and levels of operational maturity? 

Answer of Mr. Laboureix 

Proportionality is a fundamental principle that underpins the SRB’s entire approach, in testing as well as in other areas. 

IRTs apply this principle when they set testing priorities and sequences for each bank. Concretely, this means that the characteristics of each bank, namely its size, potential complexity, SREP scores and progress on resolvability conditions are taken into account when determining the MATP. 

The most complex institutions may be required to carry out more sophisticated tests earlier. The choice of testing methods will also reflect the maturity level of each bank’s capabilities.  

This calibration ensures that resolvability tests remain relevant and manageable, providing a sufficient level of assurance regarding the banks’ operational capacities while also maintaining a proportionate workload. 

In addition, MATPs are discussed and coordinated as much as possible with other resolution authorities in the case of international operations and with the prudential supervisor, for the same reason. Of course, the dialogue between our teams and the bank is yet another tool to further fine-tune the practical implementation of testing.  

7. For MPE (Multiple Point of Entry) groups or subsidiaries of non-European groups under the SRB’s remit, how does the SRB intend to coordinate operational resolvability exercises to avoid duplication and ensure group-level consistency? 

Answer of Mr. Laboureix 

For groups whose strategy is a Multiple Point of Entry (MPE), a self-assessment report is required at the level of each resolution group located in the Banking Union. Tests will also be conducted for every point of entry within the Banking Union. Specific tests aimed at ensuring the separability of resolution groups will be required from the parent company and from the other resolution groups. Here again, the SRB coordinates with the relevant national authorities for resolution groups located outside the Banking Union. 

For subsidiaries of non-European groups established in the Banking Union, the approach is coordinated within the resolution colleges and crisis management groups (CMGs) with the home authorities (for example, the Bank of England). 

For example, for hosted non-European banks belonging to a group with an SPE strategy, the SRB will align with the third-country resolution authorities regarding deadlines and priorities for tests involving the subsidiaries located in the Banking Union that contribute to the group-wide testing and assurance activities. 

8. The Testing Guidance published by the SRB distinguishes three official testing methods: (1) desktop exercises, (2) walkthroughs, and (3) dry-runs (including operational simulations, management simulations, and drills). Could you please recall the specific objectives of these different formats of resolvability tests introduced by the SRB? How should banks structure their governance, preparation, and documentation to meet the SRB’s expectations? 

Answer of Mr. Laboureix 

Indeed, our toolbox includes several testing methods! 

These methods serve different objectives, and their relevance may vary depending on the resolvability dimension being tested. 

Allow me to explain: 

The « desktop exercise » is a critical review of one or several procedures involving different actors within the bank. 

During a « walkthrough », banks must concretely demonstrate the relevance of one or several procedures by simulating the different steps. 

Finally, during a « dry-run », banks must test their resolvability capabilities based on a crisis scenario unfolding – as far as possible – in real time. 

There are several different variations possible for the dry run: 

First, the « operational simulation », which focuses on the operational steps required for the implementation of a given procedure. 

Then the « drill », which introduces an element of surprise, although banks are informed in advance through the MATP of upcoming drills. 

Finally, the « management simulation test », which places emphasis on the role played by senior management and/or the management body during a crisis event. 

9. On-site inspections (OSIs) and deep-dives are becoming key instruments of the SRB’s multi-annual program. These exercises, conducted directly by SRB teams, aim to examine on-site the concrete implementation of resolvability capabilities tested under the MATP. Although they do not strictly fall under the resolvability guidances, they follow the same logic of operational verification and complement its results. How does the SRB plan to deploy these OSIs and deep-dives in the coming years, and according to what criteria will institutions or themes be selected? How should banks prepare for these exercises? 

Answer of Mr. Laboureix 

On-site inspections and deep dives are fundamental and complementary tools we can use to assess the implementation of the regulatory framework or Expectations for Banks, as well as to deepen analyses on specific aspects. The SRB can deploy these tools with varying degrees of intrusiveness and legal implications to address different information needs. 

For example, inspections are highly formalised processes carried out by specialised and independent teams with a broader scope and generally longer duration. By contrast, deep dives are more flexible and targeted. IRTs can conduct them directly on-site using similar approaches, which, in turn, allows them to compare progress across different banks. 

The growing use of on-site inspections and deep dives contributes to the same objective of the SRM Vision 2028: to better operationalise resolution tools and promote crisis preparedness. 

Naturally, the SRB cannot test everything all the time. This is why it adopts a three-year plan that is subject to an annual review. 

This plan is drawn up based on an assessment of each bank’s resolvability, taking both quantitative and qualitative elements into account. We then coordinate with the ECB to identify potential synergies and avoid any excessive burden on the banking sector. 

The SRB tries to minimise the efforts required from each bank subject to an on-site inspection or deep dive to the extent possible. 

For instance, we inform banks several months in advance when on-site inspections and deep dives are being planned. Moreover, we invite banks to submit documents and information well in advance to shorten the presence of our teams on-site. These measures allow the SRB to act in a more proportionate way and to calibrate its investigative tools according to the bank’s resolvability and complexity. 

I would like to also use this opportunity to emphasise that the presence of SRB inspectors has so far been positively received by banks. Of course, we welcome this cooperation! 

10. Resolvability tests are not mere exercises; they directly feed into resolution planning. The SRB has indicated that the results of the MATP will inform the annual revision of the resolution plan and may lead to specific priority letters or corrective action plans when gaps are identified. How does the SRB plan to use the results of resolvability tests, OSIs, and deep-dives in its planning? Can these results lead to corrective actions, and if so, which ones? 

Answer of Mr. Laboureix: 

The development of resolvability is a continuous and joint effort between banks and the IRTs. 

There is a natural feedback loop between resolvability assessment and the entire range of tests. Testing priorities are chosen based on the assessment results, while the operational effectiveness of capabilities is verified through the tests, which, in turn, influence the next resolvability assessment. 

The insights from assessment translate into some sort of score that serves as an action plan to calibrate our requirements for loss-absorbing capacity. During this assessment, the SRB takes the observations made as well as the quality of the tests performed into account. 

Following this analysis, the SRB may decide on corrective measures to address the shortcomings identified. Of course, the measures depend on the nature of the gaps observed. For example, the SRB may ask the bank to strengthen certain teams, to develop additional data or to update certain procedures. 

The deadlines and level of follow-up by the SRB will depend on the nature of the shortcomings observed in the implementation of the resolution strategy. Naturally, if these shortcomings constitute real material deficiencies, the SRB may trigger the substantive impediment procedure, which has not been used to date. 

End of SRB transcript. 

Discover the interview on the Single Resolution Board website here.