08 · SREP, P2R & P2G
Art 97–104b CRD · EBA SREP GL
Purpose & history
How judgement becomes a number
The SREP scores four elements — business model, governance & risk management, risks to capital, risks to liquidity — each 1–4, composing an overall score that anchors P2R: a binding, MDA-relevant requirement covering risks Pillar 1 misses (concentration, IRRBB above the SOT's tolerance, model deficiencies, whatever TRIM left). Composition rule: at least 56.25% CET1 and 75% Tier 1, unless the supervisor demands more. P2G sits above the buffers: sized from stress-test depletion, not MDA-relevant, but ignoring it invites the one letter no CFO wants. The standing disciplines: no double counting with Pillar 1 (acute since the floor and SMA arrived — nominal P2R amounts were recalculated at the floor switch precisely to strip overlap), and proportionality (SREP intensity by category). ESG risks and transition-plan credibility enter the methodology from 2026 under CRD6.
Requirements
Calculations
Changes & sources
- Sources: Art 97–104b CRD; EBA SREP GL (2022); ECB SREP methodology and annual aggregate outcomes; CRD6 for ESG and third-country branches.
- Watch: P2G methodology harmonisation and the floor/P2R overlap debate — both quietly worth basis points.
Independent analysis by Elderlake Partners, as at August 2026. Not legal, accounting or supervisory advice.