The Single Resolution Board's (SRB) consultation on its updated Operational Guidance on Liquidity and Funding in Resolution goes well beyond a tidying-up exercise. It represents a targeted tightening of expectations across liquidity estimation, measurement and reporting, and collateral mobilisation.
According to Regnology, by folding its separate frameworks into one document, the regulator is signalling that these are not standalone compliance tasks but interlinked disciplines that together form a single operational capability banks must prove they hold under crisis conditions.
Regnology recently discussed building operational capability for the Single Resolution Board's updated liquidity guidance.
The Technical Meeting on the Operational Guidance confirmed that the consolidation aims to cut duplication between EfB 3.1, 3.2 and 3.3, encouraging banks to reuse existing analyses, data and frameworks wherever possible. For lenders, this marks the end of resolution planning as a theoretical, tick-box exercise.
On estimation, the Liquidity in Resolution Estimate remains the foundation of any credible resolution plan, but the SRB now demands faster, more flexible, resolution-specific modelling. The fast-moving scenario window has been cut from three months to just one month between crisis onset and entry into resolution. Banks must also consider variant resolution strategies alongside their preferred approach, and scrutinise group structures more closely, since branches and SPVs are not automatically classed as Key Liquidity Entities. Institutions following a Multiple Point of Entry strategy must ensure each resolution group manages its liquidity independently, while the SRB's Annex II template offers an optional, rather than mandatory, data structure.
Measurement and reporting expectations have sharpened too. Institutions must be able to deliver an updated liquidity position within 24 hours, potentially requiring re-run scenarios rather than simple data extraction. High-frequency reporting, including intraday information where relevant, is now expected, with the Joint Liquidity Template strongly recommended. The explicit reference to BCBS 239 underlines that data governance and lineage matter as much as the final figures themselves.
Collateral mobilisation is reframed around accessibility rather than volume. Since the SRB assumes a bank's most liquid assets may already be encumbered, the focus shifts to how quickly collateral can genuinely be mobilised, accounting for location, legal restriction and custody arrangements.
With the consultation closing on 6 July 2026 and final guidance expected in Q4 2026, application from the 2027 resolution planning cycle is proposed. Regnology product director Erik Becker said banks should prioritise a unified data foundation, a resilient modelling and governance framework, and an automated, controlled production workflow to meet the tightened requirements.