The EBA Streamlines Its Guidelines on Connected Clients to Align with New EU Legislation

Why It Matters

By aligning the guidelines with directly applicable EU law, the EBA eliminates regulatory overlap, streamlining compliance for credit institutions and ensuring a uniform approach to identifying connected client groups across the single market.

Key Takeaways

• EBA removed redundant sections from 2017 guidelines after EU Regulation 2024/1728
• New delegated regulation sets binding technical standards for identifying connected client groups
• Changes ensure uniform application of EU law across all credit institutions
• Consolidated guidelines now posted on EBA website for immediate reference

Pulse Analysis

The concept of "connected clients" has long been a focal point for European supervisors, as intertwined relationships can amplify credit risk and obscure true exposure. The original 2017 EBA Guidelines offered a detailed methodology for banks to map control relationships, economic dependency, and combined influence, helping institutions meet the Capital Requirements Regulation (CRR) and maintain robust risk‑management frameworks. Over time, however, the guidance evolved in parallel with broader legislative initiatives, creating occasional friction between supervisory expectations and statutory requirements.

Commission Delegated Regulation (EU) 2024/1728 marks a decisive shift by codifying technical standards that are directly applicable in every Member State. Unlike the advisory nature of the 2017 guidelines, the delegated regulation carries binding force, specifying precisely when banks must identify groups of connected clients. This regulatory upgrade reduces interpretive variance, accelerates supervisory consistency, and frees banks from duplicative documentation. By superseding overlapping sections of the older guidance, the EBA ensures that the supervisory toolkit remains lean, focused, and fully compliant with Union law.

For credit institutions, the practical impact is twofold. First, compliance teams can streamline their data‑collection processes, relying on a single, legally binding set of criteria rather than reconciling multiple sources. Second, the harmonized approach mitigates the risk of regulatory arbitrage, fostering a level playing field across the European banking sector. The consolidated guidelines now available on the EBA website serve as a transitional bridge, helping banks adjust their internal policies while the industry adapts to the new regulatory baseline. In the longer term, this alignment signals the EU's commitment to clearer, more efficient banking supervision, a trend likely to continue as digital finance and cross‑border activities expand.