This opinion provides the European Banking Authority's (EBA) formal response to the European Parliament's observations regarding the discharge process for the year 2024. The EBA welcomes the Parliament's approval of the closure of accounts and the decision to grant discharge to its Executive Director for the implementation of the budget. The EBA emphasizes the importance of feedback received during this process to…
This document is the official opinion of the European Banking Authority (EBA) on the 2024 discharge report of the European Parliament. It was approved by the EBA Supervisory Board on 17 August 2026. The report concerns the implementation of the EBA's budget for the 2024 financial year, within the procedures provided by the EBA Regulation (Regulation (EU) No 1093/2010) and the EBA Financial Regulation. The scope covers the European Parliament's observations related to budget management, performance, governance, transparency, compliance with fundamental rights, human resources management, cybersecurity, and financial and operational risks. The document comprises approximately 58 pages, of which the first 35 are analyzed here (p. 1-35).
The EBA's opinion responds to observations made by the European Parliament during the 2024 discharge procedure, which assesses the financial and operational management of the Union's decentralized agencies, including the EBA. The subject concerns the EBA's compliance with budgetary requirements, transparency, performance, human resources management, cybersecurity, and governance. This topic is crucial as it guarantees the proper use of public funds, stakeholder confidence, and the EBA's capacity to fulfill its mandate in an expanding regulatory context (notably DORA, MiCA, EMIR). The main findings are that the EBA obtained discharge for the 2024 fiscal year, demonstrating satisfactory management without open observations from the European Court of Auditors. The EBA integrated the Parliament's recommendations on transparency, conflict of interest management, diversity and inclusion, cybersecurity, and budget planning. However, a resource shortfall persists for new responsibilities not accompanied by additional funding, despite internal efficiency efforts. The EBA has implemented an activity-based budgeting system, ensuring transparency and a clear link between resources, activities, and strategic objectives, although differentiating between European and national funding is not feasible. The EBA respected payment deadlines, has robust ethical governance, and implemented the European cybersecurity regulation requirements. The main recommendations are to continue improving performance indicators, strengthen resource planning to cover extended mandates, and maintain a high level of transparency and compliance. These measures aim to ensure the sustainability, efficiency, and accountability of the EBA in a complex and evolving regulatory environment (p. 1-35).
This document was drafted to formally respond to the European Parliament's observations within the 2024 discharge procedure, which aims to evaluate the budget management and performance of the European Union's decentralized agencies, including the EBA. The challenge is to ensure transparency, accountability, and efficiency in the use of public funds, while guaranteeing respect for fundamental rights and the proper execution of regulatory mandates. The scope covers financial management, governance, transparency, human resources management, cybersecurity, as well as risks identified by the European Court of Auditors. The limits concern the analysis of only the first 35 pages of the report, which mainly address general observations, budget management, human resources, cybersecurity, and financial risks (p. 1-35).
- Governance and transparency: The EBA supports the Parliament's observations on the need to ensure proactive transparency, timely publication of non-confidential documents, and the establishment of rigorous conflict of interest controls. The EBA applies strict rules governing interactions with stakeholders via the Banking Stakeholders Group, with publication of meetings and responses to public consultations. The legal framework provides pre- and post-employment restrictions to avoid conflicts of interest (p. 6-7).
- Human resources and diversity: The EBA shows a near gender parity (49.76% women), with high female representation in leadership positions (60%). Geographic diversity is respected, without excessive overrepresentation of the host country nationality (France). The EBA adopted the Diversity and Inclusion Charter and received an EUAN award for its actions in 2025. Robust complaint management mechanisms, including for harassment and whistleblowing, are in place, with regular staff training (p. 8-10).
- Cybersecurity: The EBA has fully implemented European Regulation 2023/2841 on cybersecurity on time, submitting required deliverables (initial review, cybersecurity plan, risk assessment). A cybersecurity plan co-drafted with CERT-EU is underway to reach required maturity levels between 2026 and 2027. The cybersecurity function has been strengthened and integrated into the 2026-2028 IT strategy (p. 30-31).
- Budget management and financing: The EBA's 2024 budget amounts to €56.9 million, up 8.04% compared to 2023, financed 37% by the European Union and 60% by national supervisory authorities' contributions. The EBA applies an activity-based budgeting system, ensuring a clear link between resources, activities, and strategic objectives, while highlighting the practical impossibility of precisely differentiating costs between European and national funding due to the shared nature of mandates. The EBA respected payment deadlines with a very low number of late invoices and no late payment interest paid (p. 13-24).
- Mandates and resources: The EBA's mandate has expanded with increased responsibilities related to DORA, MiCA, EMIR, and the banking package (CRR/CRD, CMDI, PSD3), some of which were not accompanied by additional resources. After an initial refusal, the EBA submitted a revised request for 7 additional posts (4 permanent, 3 temporary) for 2027-2029. The agency implements internal efficiency measures, but a resource shortfall persists (p. 4-5).
- Performance and indicators: The EBA is working to improve its key performance indicators (KPIs) to be clear, measurable, and comparable over time, integrating cost-benefit analyses and transparent budgeting. The EBA supports the idea of a common framework for European agencies to harmonize these practices (p. 10-12).
- Audits and risks: The EBA has not been subject to observations or recommendations from the European Court of Auditors for 2024, demonstrating sound financial management. The agency received an unqualified opinion on the reliability of accounts and the legality of revenues and payments. Emphasis is placed on the need for all agencies to strengthen ex ante controls, notably in public procurement, even if this does not directly concern the EBA (p. 25-28).
- Established facts: The EBA obtained discharge from the European Parliament for the 2024 fiscal year, without open observations from the European Court of Auditors. The 2024 budget increased by 8.04% to €56.9 million, mostly financed by national contributions. The EBA complies with rules on transparency, conflict of interest management, diversity, complaint management, and cybersecurity. Payment deadlines are largely respected with a very low number of delays. The EBA applies an activity-based budgeting system, ensuring transparency in resource management.
- Assumptions: Precise differentiation of costs between European and national funding is not feasible due to the shared nature of mandates and benefits. Requests for additional resources for new mandates are necessary to ensure continuity and quality of missions.
- Interpretations: The EBA considers that its internal efficiency efforts and mandate prioritization allow it to manage limited resources optimally, but a shortfall persists. Transparency and rigorous governance are essential levers to maintain trust and performance.
- Uncertainties: The evolution of regulatory mandates and the capacity to obtain adequate resources remain key uncertainty factors. The impact of new regulatory requirements on workload and future resources will need close monitoring.
The EBA concludes that financial and operational management for 2024 complies with the requirements of the European Parliament and the Court of Auditors, justifying the granted discharge. The agency commits to continuing improvements in transparency, notably regarding budgeting and performance indicators, and to strengthening resource planning to meet expanded mandates. It recommends establishing a common framework for including cost-benefit analyses in the performance of European agencies. The EBA emphasizes the need for adequate funding for new regulatory responsibilities (DORA, MiCA, EMIR) and invites stakeholders to anticipate these needs in future legislative financial documents. Finally, the agency will maintain its efforts in cybersecurity, conflict of interest management, diversity and inclusion, as well as compliance with payment deadlines and budgetary rules, to ensure effective and responsible governance (p. 1-35).
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