​The EBA publishes a no-action letter and technical considerations to support the implementation of the market risk framework for EU banks

RegCanary interpretation

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This publication signals that EU banks must now align their trading book/banking book boundary classification with EBA expectations ahead of the Commission's Delegated Act on market risk own funds requirements. Compliance teams should treat this as an early readiness signal: the EBA is prioritising consistency and harmonisation across the EU, which means firms cannot rely on divergent national interpretations. The no-action letter offers temporary relief, but it comes with the clear expectation that banks will use this period to review their boundary definitions, internal risk models, and capital calculations against the FRTB-based framework. Action needed: assess current trading book classifications, identify gaps between your practice and the EBA's technical clarifications, and begin adjusting methodologies where necessary. This is especially relevant for banks with active trading operations, as the boundary between the banking book and trading book directly impacts capital requirements. Early movers will reduce implementation risk and avoid remediation burden once the delegated act is formally adopted. The technical clarifications also provide an opportunity to engage constructively with supervisors and demonstrate proactive compliance, which may smooth the approval process for internal models. Overall, this is a call to integrate the revised market risk framework into your regulatory change roadmap now, rather than waiting for the final legal text.

RegCanary impact assessment

RegCanary impact score: 10/10