Opinion in accordance with Article 131 CRD on macroprudential measures in Austria

General Information

This document is an opinion issued by the European Banking Authority (EBA) dated 30 April 2026. It concerns the macroprudential measure notified by the Austrian Financial Market Authority (FMA) aiming to increase the sectoral systemic risk buffer (SyRB) rate on exposures to the commercial real estate (CRE) sector in Austria. The scope covers exposures to non-financial corporations active in building construction, specialized construction activities, and real estate activities, excluding limited-purpose housing associations. The application period starts on 1 July 2026 with a gradual increase of the rate from 1% to 3.5% on 1 July 2027. The measure applies at consolidated, sub-consolidated, and individual levels (p. 1-2).

Executive Summary

The EBA received a notification from the Austrian FMA regarding the increase of the sectoral systemic risk buffer (SyRB) from 1% to 3.5% on exposures to commercial real estate (CRE) lending in Austria. This measure aims to mitigate identified systemic risks in this segment, which represents 34% of loans to non-financial corporations and whose non-performing loans (NPLs) have sharply increased from 1% at the end of 2022 to 8.3% at the end of 2025, with a risk of worsening under an adverse scenario (p. 2). The EBA acknowledges the relevance of this measure to limit macroprudential risks and does not oppose it. However, it notes that the sum of O-SII and SyRB buffers could exceed 5% for some institutions, notably a subsidiary of a foreign group, which could generate inefficiencies in the internal market, although the FMA considers the impact insignificant (p. 3). The EBA stresses the need for ongoing coordination between authorities to avoid overlaps with other regulatory requirements, notably Pillar 1 and 2 capital requirements, as well as the potential impact of the output floor which could become binding (p. 3-4). The SyRB increase phase will span from 1 July 2026 (2%) to 1 July 2027 (3.5%). The measure excludes limited-purpose housing associations and applies to all concerned institutions at consolidated and individual levels. In conclusion, the EBA endorses the measure while recommending continuous vigilance regarding its interaction with the overall regulatory framework (p. 1-4).

Context and Objectives

The document was drafted following the notification by the Austrian FMA of an intention to increase the sectoral SyRB on CRE exposures in Austria, pursuant to Article 133 of Directive 2013/36/EU. The objective is to address increased systemic risks in this sector, notably the rise in NPLs and the potential impact on the stability of the banking system and the Austrian real economy. The measure aims to strengthen banks' resilience to these risks. The scope excludes limited-purpose housing associations. The notification specifies a phased implementation. The EBA intervenes to assess the measure's compliance with the European framework, its impact on the internal market, and interactions with other prudential requirements. The document does not address other sectors or countries (p. 1-2).

Summary of Key Points by Theme

Identification of systemic risks: The commercial real estate lending sector in Austria represents 34% of loans to non-financial corporations. The non-performing loan rate rose from 1% at the end of 2022 to 8.3% at the end of 2025, with a risk of increase under an adverse scenario, justifying a macroprudential intervention (p. 2).

Measure and calibration: The FMA proposes to increase the sectoral SyRB from 1% to 3.5%, with a transition phase between July 2026 (2%) and July 2027 (3.5%). This calibration is based on a stress test analysis using the 2025 European stress test scenario for Austria, taking into account the limited impact of CRR3 regulatory changes on risk weights of targeted exposures (p. 2-3).

Interactions with other buffers: Some affected banks are subject to O-SII buffers, bringing the sum of O-SII and SyRB buffers to 5.75%-6.25% on targeted exposures. A subsidiary of a foreign group is particularly concerned, which could generate inefficiencies in the internal market, although the FMA considers the impact limited (p. 3).

Regulatory coordination: The EBA highlights the need to avoid overlaps with other prudential requirements, notably Pillar 1, Pillar 2, and Pillar 2 Guidance, as well as to monitor the impact of the output floor which could affect institutions using the IRB approach for capital requirements calculation (p. 3-4).

Impact on the internal market: The FMA's analysis does not identify significant effects on the European internal market, despite high combined buffer levels for some institutions (p. 3).

Exclusions: Limited-purpose housing associations are excluded from the scope of the measure (p. 1-2).

Main Findings and Lessons Learned

Findings: The NPL rate on CRE exposures in Austria has sharply increased from 1% at the end of 2022 to 8.3% at the end of 2025, constituting a proven systemic risk. The sector represents a significant share of the loan portfolio to non-financial corporations (34%). The proposed measure increases the sectoral SyRB from 1% to 3.5% with a phased application (p. 2).

Assumptions: The stress analysis is based on the 2025 European stress test scenario. The impact of CRR3 regulatory changes on risk weights is considered limited by the FMA, justifying an increase in the SyRB (p. 2-3).

Interpretations: The EBA considers the measure justified to limit macroprudential risks related to CRE in Austria. It notes however that the combination of O-SII and SyRB buffers may generate inefficiencies, notably for a subsidiary of a foreign group, and recommends enhanced coordination between authorities (p. 3).

Uncertainties: The future impact of the output floor on affected institutions remains to be monitored. Moreover, the combined effect of different prudential requirements requires follow-up to avoid overlaps and unnecessary capital burdens (p. 4).

Conclusions and Recommendations

The EBA does not oppose the increase of the sectoral systemic risk buffer from 1% to 3.5% on CRE exposures in Austria, recognizing the need to address identified systemic risks. It nevertheless recommends ongoing coordination between national and European authorities to avoid overlaps with other prudential requirements, notably O-SII buffers, Pillar 1, Pillar 2, and the output floor. The EBA stresses the importance of careful monitoring of the measure's impact on the internal market, particularly for subsidiaries of foreign groups, to prevent any inefficiency in intra-group capital flows. Finally, it recalls the need to reassess the measure if the output floor becomes binding for the targeted institutions (p. 3-4).