Proposed Directive - Replacement of D11 of 2025

It also clarifies how banks should apply regulation 67 of the Regulations relating to Banks. For compliance teams, the key task is to compare the proposed replacement with existing D11 policies, classification rules, data lineage and regulatory reporting outputs. Banks should involve credit risk, finance, legal and reporting teams to assess gaps in exposure identification, restructuring triggers, staging, capital treatment and disclosure.

The proposal may require updates to credit policies, systems configurations, governance approvals and report specifications. Although no consultation deadline is stated in the provided content, firms should monitor for finalisation and implementation dates and consider whether a consultation response is warranted. The directive reinforces supervisory focus on consistent, transparent treatment of restructured credit, making data quality and early remediation important.

Actions: map current processes to the proposal, document gaps, validate reporting data, brief senior management and track the final directive.