Consultation response to EBA on the implementation of the expected credit losses model

In our response to the European Banking Authority (EBA), we welcome its initiative to ensure sound credit risk management practices and accounting for expected credit losses (ECL) within the EU. We are concerned that the scope of application of the proposed guidelines is wider than the scope of the Guidelines issued by the Basel Committee on Banking Supervision on the same topic.

Any alignment at EU level should stay as close as possible to international requirements and guidance such as from the Basel Committee to ensure consistent interpretations of IFRS 9 and achieve a high-quality ECL model across different jurisdictions. We expect that EBA does not intend to have the authority to establish requirements for financial statements.