Bank directors in SSM declare higher time commitment to roles
The ECB's Single Supervisory Mechanism (SSM) has updated its benchmarking data on the declared time commitment of non-executive directors. The report, based on data from 2022 to 2025, reveals a significant increase in their average time commitment to supervisory roles.
Time commitment rises across SSM banks
The ECB has updated its benchmarking exercise on the declared time commitment of non-executive directors (NEDs) within the Single Supervisory Mechanism (SSM).
This new report, based on data collected from the first quarter of 2022 to the first quarter of 2025, covers a significantly broader sample of 4,200 individual assessments across 692 different entities, representing all 114 directly supervised banking groups.
The findings indicate a substantial increase in the average time commitment.
Non-executive directors now declare an average of 28 days per year to their functions, up from 22.2 days in the 2019 exercise.
For non-executive chairs, the declared commitment rose from 41.6 days per year in 2019 to 64.2 days per year in 2025. This positive trend suggests that the previous benchmarking report had a meaningful impact on governance standards, fostering better understanding of factors affecting directorship time and encouraging alignment with supervisory expectations.
Beyond the numbers: Assessing director engagement
The ECB assesses non-executive directors' time commitment on a case-by-case basis, applying proportionality and considering both quantitative and qualitative factors.
While the Capital Requirements Directive (CRD) sets limits on directorships (e.g., one executive and two non-executive, or four non-executive roles), merely meeting these quantitative thresholds is often insufficient.
The ECB also considers qualitative aspects such as the entity's size and complexity, travel requirements, and the director's overall experience and other commitments.
Despite the observed increase in declared time commitment, recurring concerns persist in fit and proper assessments.
These issues primarily relate to directors holding an excessive number of positions, declaring a high overall time commitment, or allocating insufficient time to their specific role within the supervised entity.
These persistent challenges underscore the ongoing need for supervisors to ensure adequate engagement for effective board functioning.
Progress, but persistent challenges
The reported increase in time commitment is a positive step, reflecting greater awareness and the impact of prior supervisory guidance.
However, the persistence of concerns regarding over- or under-commitment for a notable share of directors suggests formal declarations don't always translate into effective oversight.
This highlights that ensuring the qualitative effectiveness of directors remains a critical supervisory challenge.