As part of a suite of policy measures to restore confidence in the EU banking sector, the EBA, in December 2011, issued a Recommendation to national authorities that participating EU banks raise their Core Tier 1 ratio (CT1) to 9%, after setting an additional buffer against sovereign risk holdings. The objective of the entire Recommendation was to ensure sufficient capital against unexpected losses if the economic situation deteriorated further.

The EBA identified a shortfall for 27 banks of €76bn1, to be addressed by end-June 2012 via an increase of the capital elements of the highest quality and via a limited set of actions aimed at reducing risk weighted assets (RWAs), without impacting lending into the real economy. Comprehensive measures have subsequently been implemented by banks to comply with the Recommendation by end-June 2012. The relevant banks submitted their capital plans to National Supervisory Authorities (NSAs) in coordination with the EBA. These plans were discussed in supervisory colleges, where host supervisors had the opportunity to raise any concerns on those measures having an impact on their own jurisdictions and credit markets.

On 11 July 2012, the EBA published a preliminary report on the implementation of banks’ capital plans. The current report presents the final outcome following an extensive collection of actual data2 provided by banks based on their financial statements as of 30 June, The outcomes and findings of this final assessment are in line with our July preliminary report.

The vast majority of the banks3 involved in the EBA capital exercise show a CT1, as of end of June, above the 9% after accounting for the sovereign buffer. In the case of four banks4, backstops are currently being undertaken, with the explicit support formally endorsed by the corresponding governments.

The capital exercise, which triggered a deep restructuring process for 4 of the banks with an initial shortfall, has resulted in an aggregate €115.7bn recapitalisation for the 27 banks after the implementation of their respective capital plans.

Overall, taking into account the capital strengthening of the remaining banks in the sample, and the capital injection already realised in Greek and Spanish banks involved in the exercise, more than €200bn have been injected between December 2011 and June 2012.

Compliance with the Recommendation has been achieved mainly via new capital measures (retained earnings, new equity, and liability management), and to a lesser extent, by releasing capital through measures impacting RWAs.

The recapitalisation exercise was a necessary step on the road to repairing EU banks’ balance sheets. It is one of a series of coordinated policy measures agreed by the European Council last October. Although the external environment remains very challenging, the recapitalisation has contributed to strengthening the capital base of the banking system and has put banks in a stronger position to continue lending to the real economy. Along with the ensuing ECB long-term refinancing operations, which alleviated the liquidity tail risk of EU banks, the recapitalisation exercise is a major step towards gradually restoring access to market funding.

The EBA will now continue to monitor banks’ capital levels. The implementation of the CRD IV/CRR framework will change the legal setting for assessing capital levels. To that end, when the final CRD IV/CRR package enters into force, the EBA intends to issue a new Recommendation. That Recommendation will replace the 9% CT1 ratio with a capital conservation requirement. Under this requirement, supervisors will monitor a nominal capital amount (e.g. Euros) which comprises the 9% CT1 as of June 2012. This level will be monitored by the consolidating supervisor, in conjunction with the EBA and Supervisory Colleges to ensure it is maintained. In addition, supervisors will assess banks’ capital plans for the transition to CRD IV/CRR implementation, including in stressed scenarios under the EBA’s 2013 EU-wide stress test. Further measures to conserve capital, such as restrictions on dividends and other variable payments, may be applied if these plans are in doubt.