Key Takeaways From the ECB’s Opinion on Proposed Revisions to the EU Securitisation Regulation

On 11 November 2025, the European Central Bank issued a detailed Opinion on the proposed amendments to the EU Securitisation Regulation (Regulation (EU) 2017/2402), as well as related changes to the CRR (Capital Requirements Regulation) and liquidity rules.

Against a backdrop of regulatory recalibration, financial stability concerns, and evolving market dynamics, the ECB’s observations provide clear signals about where the securitisation market in Europe may be headed.

Here are the key takeaways from the ECB’s opinion, structured around its three main focus areas: regulatory reform, prudential supervision, and monetary policy implications.

1. The objectives of the regulation together with financial stability considerations,
2. Prudential supervision considerations,
3. Monetary policy aspects.

The opinion also focuses on the ECB’s competence to supervise compliance with the STS criteria, among other issues. More specifically, there are some observations related to:

The ECB comments on several key changes proposed to the Securitisation Regulation including:

• 1a. simplification of investor due diligence,
• 1b. relaxation of certain risk retention requirements
• 1c. simplification of disclosure requirements
• 1d. amendments to the STS criteria, and
• 1e. amendments to the definition of public securitisation.

This part examines how the proposed CRR changes would impact the overall framework for assessing, structuring, and managing securitisation exposures.

• 2a. amendment to the definition of senior securitisation position
• 2b. introduction of the concept of resilient position
• 2c.amendment to the risk weight floors
• 2d. amendment to the p factor in the calculation of risk weights for securitisation positions,
• 2e. general considerations on the proposed changes to the capital treatment of securitisation positions,
• 2f. amendments to the SRT criteria, and 2g. SRT process.

Part 3 deals with the proposed amendments related to the liquidity coverage ratio (LCR) delegated regulation. It refers to the amendments related to the treatment of securitisation positions as liquid assets. The observations in this section focus on:

• 3a. the eligibility of securitisation positions as liquid assets under the LCR framework,
• 3b. the interaction between the LCR treatment and the STS requirements,
• 3c. the criteria and conditions for recognising securitisation instruments as Level 2B assets,
• 3d. the role of transparency and data availability in assessing liquidity characteristics, and
• 3e. considerations related to maintaining consistency with international liquidity standards.

To access the ECB’s Opinion Paper, please click the button below.

The ECB’s Occasional Paper No. 378, published in mid-November 2025, provides a comprehensive analysis of the role played by the temporary and country-specific Additional Credit Claims (ACC) frameworks within the Eurosystem collateral framework. The paper reviews how the ACC tool has evolved since its introduction in 2012 and examines its effects over time, including a comparison with the impact of asset-backed securities (ABS) and covered bonds. These assessments are supported by several illustrative graphs.

The paper highlights several key lessons:

• The ACC framework proved to be particularly effective during periods of market stress, demonstrating strong implementation results in crisis environments,

• Understanding bank-specific characteristics and the broader financial context is crucial when designing collateral measures,

• Carefully designed collateral expansions can help address challenges linked to a heterogeneous banking system,

• Accepting additional, riskier collateral can—in some cases—be more risk-efficient than lowering haircuts on assets already mobilised,

• Ensuring robust credit assessment systems for the additional collateral remains an essential operational prerequisite,

• Operational readiness is vital, as it enables faster mobilisation of collateral when institutions face urgent liquidity needs.