Núñez proposes merging CCyB and SyRB into single buffer
Banco de España Deputy Governor Soledad Núñez proposed merging the countercyclical and systemic risk buffers into a single releasable instrument on September 18, 2026. The reform aims to simplify European banking capital rules while maintaining sector resilience.
One buffer to replace two
Under the proposal, European macroprudential authorities would eliminate the Systemic Risk Buffer (SyRB) and subsume it into a redefined Countercyclical Capital Buffer (CCyB).
Recent crises, including the pandemic and geopolitical conflicts, showed that financial distress often emerges without preceding credit booms.
Núñez noted that authorities have stretched the SyRB to build capital, creating ambiguous trigger criteria and regulatory overlap.
A unified, releasable macroprudential buffer would formalize the positive neutral rate, enabling authorities to accumulate capital during normal times.
Because the SyRB is an EU-specific tool, removing it avoids Basel compliance issues while accommodating sectoral risks via a sectoral CCyB.
Flexibility across divergent cycles
Núñez endorsed European Central Bank proposals to reduce tool proliferation and preserve the central bank's top-up authority.
However, she rejected centralized methodologies in Level 1 legislation, pointing to past difficulties with the rigid credit-to-GDP gap formula.
National authorities require methodological flexibility because economic and financial cycles differ across Banking Union member states.
She cautioned that centralizing rules before financial cycles converge risks repeating the ownership problems seen under earlier European fiscal frameworks.
Sensible cleanup, familiar turf war
Merging the buffers sensibly reduces macroprudential clutter across European banking systems.
However, Madrid's pushback against centralized methodologies reflects persistent friction between national watchdogs and Frankfurt.
Harmonizing capital rules will remain difficult until member states share synchronized financial cycles.