No. 104 - Resolution Authorities and their institutional settings in EU Member States

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by Raffaele D'Ambrosio and Diane FromageJune 2025

The issue No 104 of the Quaderni di ricerca giuridica examines how EU Member States have implemented the requirements set in Article 3 of the BRRD regarding the institutional framework of the national resolution authorities, ten years after the Directive was adopted.

To understand how the resolution function is organised across the 27 EU Member States, each State's regulatory and institutional framework was examined, with dedicated reports illustrating the salient features of each framework. Three further reports set out the views of the EU authorities involved in the EU resolution regime: the EBA, the SRB and the ECB. A summary of the main features of the several national regimes is provided in the form of summary tables at the end of the collection of reports to facilitate a comparison between the different organisational solutions adopted.

The study highlights, among other things, that the separation of supervisory and resolution authorities, which is desired but not imposed by the BRRD, is, in practice, the exception rather than the rule. Instead, solutions aimed at ensuring the separation of functions and the exchange of information within the same authority prevail, albeit with the inevitable nuances of the various organisational models linked to national specificities.