European Central Bank Banking Supervision published a report updating its benchmarking of the declared time commitment of non-executive directors (including chairs) across the Single Supervisory Mechanism, using fit and proper assessments conducted from the first quarter of 2022 to the first quarter of 2025. The updated dataset points to higher declared time spent on supervised bank roles and per board meeting than in the 2019 exercise, while noting that concerns about overstretched directors and low engagement persist; the report is descriptive and does not set new requirements or supervisory expectations. The benchmarking covers 4,200 individual assessments from 692 entities across all 114 banking groups directly supervised by the ECB, including 461 chair positions. Non-executive directors declared an average of 28 days per year for their role in the supervised entity (22.2 in 2019), while chairs declared 64.2 days per year on average and the report compares 2019 with 2025 as rising from 41.6 to 56.9 days per year; declared commitments varied widely (10 to 60 days for directors and 15 to 200 for chairs). Time allocation increased with entity size and complexity, including an average of 52.7 days per year for non-executive directors in entities above EUR 100 billion in total assets versus 30.3 days in entities below EUR 2 billion, and was higher for directors with committee responsibilities. Directors declared 3.9 days per board meeting on average (2.8 in 2019) and chairs 4.6 (3.5 in 2019); the ECB also reports a slight rise in total directorships (to 4.0 for directors and 4.6 for chairs) and higher overall declared commitments across all positions (195.5 days per year for directors and 199.7 for chairs). The report reiterates that, beyond the Capital Requirements Directive limits on directorships for members of management bodies in significant institutions, the ECB assesses time commitment case by case and may seek additional information where the overall workload raises concerns. The ECB will continue to scrutinise time commitment in fit and proper assessments and ongoing governance supervision, using benchmarking and peer comparisons to support targeted follow-up on material discrepancies.
European Central Bank - Banking Supervision 2026-02-11
European Central Bank Banking Supervision updates SSM benchmarking on non-executive directors’ declared time commitment
The European Central Bank Banking Supervision updated its benchmarking report on non-executive directors' time commitment across the Single Supervisory Mechanism, based on assessments from 2022 to 2025. The report highlights increased declared time spent on roles and board meetings compared to 2019, with persistent concerns about overstretched directors. It does not set new requirements but emphasizes ongoing scrutiny of time commitments in governance supervision.