CRR 2026 Technical Standards: What Banks and Investment Firms Must Review

Key data

Compliance departments of banks and investment firms have a specific task on their agenda: to review that their internal documentation and procedures use the updated terminology and references established by the Delegated Regulation (EU) 2026/807, published on 7 July 2026.

The change does not affect the substance of prudential capital obligations. What changes is the technical layer: the regulatory references and terminology that the financial sector must use when applying the standards derived from the Regulation (EU) No 575/2013 (CRR), the framework that regulates prudential capital requirements for credit institutions and investment firms throughout the European Union.

What does this regulation establish?

Delegated Regulation (EU) 2026/807 amends the Delegated Regulation (EU) 2023/206, which contains regulatory technical standards (RTS). The reason: Regulation (EU) No 575/2013 (CRR) was amended after the publication of Regulation 2023/206, which created misalignments between the references and terminology used in the technical standards and the updated text of the CRR.

The following table summarises the two axes of change:

The result is greater terminological consistency in the uniform application of prudential regulation throughout the EU, making it easier for all financial entities to interpret and apply the rules in the same way, regardless of the Member State.

Economic and operational impact

The direct economic impact of this regulation is limited: the required capital ratios are not modified, nor the calculation methods, nor the prudential thresholds. There are no new substantive obligations that would entail additional capital costs or provisions.

The operational impact, however, is relevant for compliance and risk control departments. Affected entities will need to:

• Review internal compliance documentation to identify references to Delegated Regulation (EU) 2023/206 or the CRR that use outdated terminology or references.
• Update internal policies, procedures and manuals that cite the affected technical standards.
• Verify that reporting systems and risk models that reference CRR terminology are aligned with the new wording.

The operational cost will depend on the volume of internal documentation of each entity and the degree of automation of its compliance processes. For entities with updated regulatory management systems, the effort will be minimal. For entities with extensive documentation and manual processes, it may require a systematic review.

Who does it affect?

• Credit institutions subject to Regulation (EU) No 575/2013 (CRR): commercial banks, savings banks, credit cooperatives and other entities authorised to accept deposits.
• Investment firms subject to the CRR: investment firms providing investment services and falling within the scope of the capital requirements regulation.
• Compliance departments of the above entities.
• Risk control departments that use CRR terminology and references in their models and reports.
• Legal advisers and consultants providing compliance services to financial entities.

Practical example

A medium-sized Spanish bank has a prudential compliance manual that references the Delegated Regulation (EU) 2023/206 and uses CRR terminology in its version prior to the latest amendments. Following the publication of Delegated Regulation (EU) 2026/807, that manual contains references and terms that are no longer aligned with current regulation.

The Compliance department will need to locate all mentions of Regulation 2023/206 and the CRR in its internal documentation, compare them with the new harmonised wording, and update the affected texts. If the bank uses an automated regulatory management system that tracks changes in the OJEU, the process can be completed in hours. If the review is manual, it may involve several days of work by the compliance team.

The risk of not doing so is not an immediate sanction for this technical change, but it does create a risk of regulatory inconsistency that can complicate internal audits, supervisory inspections or the defence of positions before the regulator.

What should companies do now?

1. Identify affected documentation: Locate all internal documents (policies, procedures, manuals, risk models, reports) that reference Delegated Regulation (EU) 2023/206 or use CRR terminology.
2. Review regulatory references: Compare citations to the CRR and Regulation 2023/206 with the new harmonised wording established by Regulation 2026/807 to identify misalignments.
3. Update documentation: Correct outdated references and terminology in all identified documents, prioritising those most used in supervision and inspection.
4. Inform risk control teams: Ensure that risk teams are aware of the terminological changes to apply them correctly in their models and reports.
5. Record the update process: Document the reviews carried out as evidence of due diligence in case of supervisory inspections.

Official source

Consult the full regulation at official source

Disclaimer: This article is for informational purposes only and does not constitute legal advice. For specific decisions, please consult a qualified professional. Source: https://eur-lex.europa.eu/./legal-content/AUTO/?uri=OJ:L_202600807