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Financial Services and Pensions Ombudsman published annual Overview of Complaints
On 26 March 2025, the Financial Services and Pensions Ombudsman (FSPO) published its annual ‘Overview of Complaints’ outlining statistics on complaints received and closed by the FSPO during 2024. In total, 6,185 complaints were received in 2024.
A contributing factor to the number of complaints in this period was those received relating to ‘disputed transactions’ in the banking sector. Nearly a third of all banking complaints included conduct grouped under ‘disputed transactions’, a 12% increase in the number of complaints in this category since 2023.
Conduct complained of within this grouping include fraudulent transactions, unauthorised withdrawals, failure to provide accurate account information, failure to provide security measures and non-receipt of money.
Overall, the banking sector represented the largest category of complaints received at 55% of all complaints (3,404). This was a decrease in complaints compared to 2023 (3,850). Most banking complaints concerned bank accounts (1,787), followed by mortgages (760) and consumer credit (442).
For all complaints that closed in 2024 the average time from receipt of complaint to closure, was 8.4 months. For non-tracker mortgage complaints that closed in 2024, the average time from receipt to closure, was 7.2 months.
EBA releases the draft of the technical package for its 4.1 reporting framework
On 27 March 2025, the European Banking Authority (EBA) published a draft technical package for version 4.1 of its reporting framework. The draft technical package provides the standard specifications that include the validation rules, the DPM and the XBRL taxonomies to support the following reporting obligations:
The final version of the technical package for the 4.1 reporting framework will be published at the end of May 2025 and will include possible corrections coming from the revision of the technical package by various stakeholders.
EBA identifies payment fraud, indebtedness and de-risking as key issues affecting consumers in the EU
On 26 March 2025, the EBA published the 9th edition of its biennial Consumer Trends Report for 2024/25 (the report). The report identified payment fraud, indebtedness, and de-risking as the most important issues affecting EU consumers.
The report summarises the input the EBA has received and concludes that payment fraud is still the most significant issue for EU consumers. This also reflects the emergence of new types of fraud such as ‘social engineering techniques’.
Indebtedness emerges as the second most relevant issue reported to the EBA, with a significant rise of what is referred to as ‘buy-now-pay-later’ credit and other types of small, fast, accessible and short-term credit.
De-risking is the third most relevant issue reported to the EBA, with more consumers facing increased difficulties in opening and retaining payment accounts, access to which is a prerequisite for residents in the EU to be able to participate in the EU economy.
Following these findings, the EBA will consider which actions to take in 2025/26 to address the topical issues identified in 2024/25 and with the aim of further enhancing consumer protection across the EU.
ECB Annual Report on supervisory activities 2024
On 25 March 2025, the European Central Bank (ECB) published the 2024 annual report on supervisory activities. The report demonstrated that overall, banks under European Banking supervision displayed great resilience, with strong capital and liquidity positions. However, looking ahead, banks must adapt to the changing environment and remain vigilant to sustain and strengthen the current levels of profitability.
The supervisory priorities for 2024-2026 will include the following:
EBA updates methodology on the regulatory and supervisory equivalence of non-EU countries
On 24 March 2025, the EBA published its updated methodology for the assessment of regulatory and supervisory frameworks of non-EU countries. The changes reflect the amendments to the Capital Requirements Regulation ((EU) 575/2013) (CRR) and Capital Requirements Directive (2013/36) (CRD).
The methodology used to perform the assessment of the jurisdiction’s regulatory and supervisory framework is based on the following two questionnaires:
As part of these updates, the EBA has also streamlined its second step questionnaire aiming to improve the overall user experience.
European Commission launches consultation on the application of the market risk prudential framework
On 24 March 2025, the European Commission began a consultation on the application of the EU’s prudential framework for market risk. The European Commission postponed the date of the application of the new market risk own funds requirements for one year. The European Commission is considering acting under Article 461a of the Capital Requirements Regulation to adopt a Delegated Regulation by the end of June 2025.
The European Commission noted in their statement launching the consultation that “recent developments in the US and UK give no clarity on the future implementation of the Basel standards in these jurisdictions. This raises questions regarding the international level playing field and the impact on EU financial markets, and the possible EU response to address these concerns.”
The deadline for comments on the consultation is 22 April 2025.
The digital euro: maintaining the autonomy of the monetary system
On 20 March 2025, Philip Lane, Executive Board member of the ECB and chief economist, delivered a keynote speech at University College Cork Economics Society Conference 2025, discussing why it is “imperative for the ECB to introduce a digital euro”. Lane outlined the roles of central bank and commercial bank moneys, the necessity of preserving the monetary autonomy or Europe and the benefits of the digital euro for Europe’s Economic and Monetary Union.
Lane further expressed that Europe requires a digital euro to “counter the foothold of dollar-linked stablecoins” and US e-payment systems in the financial system, noting that the prevalence of electronic payments provided by firms such as Apple Pay, Google Pay and Paypal exposes Europe to “risks of economic pressure and coercion”. It was suggested a digital euro would reduce reliance on these providers and provide a “secure, universally accepted digital payment option under European governance”.
EBA publishes final report with draft ITS on the joint decision process for internal model authorisation
On 17 March 2025, the EBA published its final report containing draft ITS amending Implementing Regulation (EU) 2016/100 specifying the joint decision process regarding the application for certain prudential permissions pursuant to CRR.
The focus of the EBA in the draft amending ITS is the facilitation of a joint decision process between the consolidating supervisor and the relevant competent authorities regarding applications for permissions referred to in in Article 143(1) and Article 151(9), Article 283, and Article 325az of CRR. The content and objectives in this mandate were not altered from the previous mandate however it revised the scope for the internal model set out in the CRR, with the possibility of applying the advanced measurement approach no longer required for operational risk.
ESMA clarifies the treatment of settlement fails with respect to the CSDR penalty mechanism
On 14 March 2025, the European Securities and Markets Authority (ESMA) published a statement on the treatment of settlement fails with respect to the Central Securities Depositories Regulation (CSDR) penalty mechanism, following the February 2025 major incident that affected TARGET Services (T2S and T2).
The ESMA statement clarifies that there is no expectation of the national competent authorities that CSDs will apply cash penalties in relation to settlement fails for the days of 27 and 28 of February 2025.
On 27 February 2025 a major incident occurred that was caused by a failure of the infrastructure component. This adversely affected T2S and T2 which meant that settlement instructions, payment instructions, ancillary system instructions or liquidity transfers between TARGET Services could not be processed for several hours.
As set out in an existing CSDR Q&A, cash penalties shouldn’t be applied in situations where settlement cannot be performed for reasons that are independent from the involved participants.
Eurosystem to offer verification of payee service
On 10 March 2025, the ECB announced that the Eurosystem had concluded its exploratory work for offering a ‘verification of payee’ (VoP) service for payment service providers (PSPs). This work builds on the services developed by the Banco de Portugal and Latvijas Banka.
The decision to offer the VoP service will help PSPs in the Single Euro Payments Area (SEPA) to comply with their legal obligations for credit transfers in euro.
Two solutions have been designed in accordance with the VoP scheme developed by the European Payments Council. The solutions will be offered by Eurosystem central banks and will have SEPA-wide reach, benefitting from the coordination by the Eurosystem. Therefore, any PSP in the euro area will be able to fulfil its obligation to offer a VoP service to their customers by 9 October 2025, using one of the two solutions.
The introduction of a VoP service is intended to reduce the risk of fraud and payment errors by allowing payers to verify the account details of the recipients before payments are initiated. This service will be available for instant payments including those settled in TARGET Instant Payment Settlement, as well as for SEPA credit transfers.
EBA consults on new rules related to the anti-money laundering and countering the financing of terrorism package
On 6 March 2025, the EBA opened a public consultation on four draft regulatory technical standards (RTS) that will be included as part of the EBA’s response to the European Commission’s call for advice on the AML/CTF mandates.
The RTS will be central to the EU’s new AML/CFT regime and will shape how institutions and supervisors will comply with their AML/CFT obligations under the new AML/CFT package.
The proposed RTS focus on the following aspects for which the EBA is providing its advice on:
The consultation runs until 6 June 2025.
For more information on these topics please contact any member of A&L Goodbody's Financial Regulation Advisory team.
This publication provides an overview of certain legal and regulatory developments that may be of interest to certain entities. It does not purport to provide analysis of law or legal advice and is strictly for information purposes only.