EBA Work Programme 2027

The programme provides valuable insight into the areas that financial institutions can expect to receive increased regulatory attention across the EU. This work programme outlines the key areas of focus and deliverables for 2027. This work programme is released annually and provides insight into the areas of scrutiny Firms can expect from the regulatory authority.

Three cross-cutting drivers

The EBA frames its 2027 agenda around three key drivers:

• Resilience – the ability to withstand geopolitical, macroeconomic, cyber and operational shocks.
• Efficiency – reducing unnecessary regulatory burden, simplifying reporting and supporting competitiveness.
• Transformation – addressing AI, digital assets, crypto, tokenisation, cloud and other technology risks and opportunities.

The EBA explicitly links its work programme to the European Commission's competitiveness agenda, suggesting a stronger focus on proportionality, simplification and reduction of supervisory burden, while maintaining prudential standards. The themes of “cost-cutting,” “competitiveness” and “simplification” are repeated throughout the document.

Seven key activities

The EBA organises its 2027 agenda around seven core activities which collectively support its objectives of resilience, efficiency and transformation:

Policy development

This activity focuses on a number of key policy developments and the finalisation of ongoing regulatory and legislative packages. The key items under this activity are the finalisation of the 2024 banking package and the implementation of the new payment services framework. The banking package is expected to be reviewed with a supervisory simplification lens. The EBA is expected to confer 18 mandates under the payment services framework. The EBA expects to deliver a first batch of five mandates and will publish Consultation Papers for a second batch of four mandates under this framework next year. The EBA also outlines the expected work on the implementation of the crisis management and deposit insurance reform as well as supporting the Savings and Investment Union and securitisation framework.

The specific policy development activities are prefaced by a general consideration of focusing on a clearer, more explicit and more systematic articulation of proportionality in the design and presentation of all EBA outputs, including reports, guidelines, technical standards, impact assessments and consultation or discussion papers. This has been recommended by the EBA’s Advisory Committee on Proportionality (ACP).

Supervisory convergence and enforcement

The EBA’s area of focus under this activity is mainly directed towards a new supervisory convergence framework. The EBA are aiming to implement a convergence framework based on:

The new convergence framework is based on:

• A supervisory convergence cycle, based on 4 pillars (risk identification/planning / execution/follow-up).
• Structured evidence collection – stakeholder input will be gathered in early 2027 and the EBA intend to identify the most impactful supervisory convergence topics, assess them consistently and prioritise them for action, driving convergence activities in future work programmes
• A clearer framework for the types of convergence activities carried out, from the establishment of supervisory expectations, capacity-building and supervisory training, to assessment through peer reviews and enforcement in potential breach of Union law investigations and mediations between Competent Authorities. 

The EBA also specifies that it intends to monitor consistent implementation of SREP and Pillar 2 with a focus on IRRBB and liquidity, while strengthening supervisory technological capacity and, as always, aims to continue to protect consumers.

Risk and financial stability analysis

The EBA states that they will enhance their risk and financial stability analysis by simplifying the EU-wide stress tests. This simplification has led to a 55% reduction in data points to be submitted year on year. The EBA will also prepare crisis simulation exercise for competent authorities and will continue to track risks to consumers and analyse ICT incidents and cyber threats.

Oversight and supervision

The EBA will focus this activity on three distinct regulatory framework areas:

1. DORA oversight of critical ICT providers
2. MICA supervision
3. EMIR initial margin model validation

Data

Regulatory reporting simplification remains a central theme. The EBA intends to further streamline reporting requirements, improve data collection processes and reduce the costs associated with regulatory compliance while maintaining the quality of supervisory data. The theme of cost-cutting and simplification is reiterated throughout the programme, and many Firms will be glad to see this agenda highlighted in relation to regulatory reporting.

Governance

The EBA's governance agenda focuses on strengthening its internal decision-making, organisational framework and international cooperation to ensure it can effectively deliver its expanding regulatory mandate.

Operations

Operationally, the EBA intends to continue investing in its internal capabilities, with a particular focus on IT security, digital tools, operational resilience and securing new premises.

How Forvis Mazars can help

Our prudential risk experts recognise that the financial regulatory landscape in Europe is constantly evolving due to new technologies and developing risks. Our experts can help Firms ensure that they understand and are appropriately prepared for regulatory developments.

We support clients in developing and enhancing regulatory change programmes, including updating existing frameworks, processes and documentation, as well as creating compliant frameworks and benchmarking against market participants.