Single Resolution Board chair calls for rethinking intragroup pre-positioning to reduce internal barriers in the Banking Union

The Single Resolution Board (SRB) published a Eurofi article by Chair Dominique Laboureix arguing that deeper Banking Union integration should include a progressive removal of internal capital and liquidity barriers within cross-border banking groups and a reconsideration of intragroup pre-positioning, with resolvability kept central. The article highlights that the single rulebook, the Single Supervisory Mechanism and the Single Resolution Mechanism have reduced fragmentation, with the SRB and national resolution authorities taking joint decisions in resolution planning and crises. It points to remaining gaps in harmonisation, notably insolvency laws and deposit guarantee schemes, while noting that the Crisis Management and Deposit Insurance package brings improvements. As evidence of progress, it cites resolution plans for major European lenders, a Single Resolution Fund of EUR 80 bn, substantial bank loss-absorption buffers and resolution experience across different Member States. For groups under a Single Point of Entry resolution strategy, it argues extensive pre-positioning is less relevant for certain banks, though internal minimum requirement for own funds and eligible liabilities remains important, while a Multiple Point of Entry strategy can justify higher pre-positioning. Laboureix links persistent home-host frictions to residual mistrust and an incomplete Banking Union, including the absence of a European Deposit Insurance Scheme and a common public liquidity backstop. He argues that current legislation leaves limited room for manoeuvre and that further integration will likely require targeted Level 1 changes and a strengthened crisis management toolkit, notably improved liquidity in resolution.