The loud two thirds: Claudia Buch counts who has a say on bank rules, and who is missing

On Tuesday 15 September 2026, Claudia Buch, Chair of the Supervisory Board of the European Central Bank (ECB), opened the first conference on “Watching European Financial Market Regulation and Supervision” at Goethe University Frankfurt. Her subject was not a new rule but the question of who gets a say on rules. According to the speech text published by ECB Banking Supervision, the European Commission consultation on the competitiveness of the banking sector drew 227 responses: 43 per cent from business associations, 16 per cent from individual banks, 8 per cent from other firms, around two thirds from the private sector in total. Public authorities accounted for 14 per cent; academia, trade unions, non-governmental organisations and citizens together for 19 per cent. “Often, banks are the most vocal in public debates,” Claudia Buch said, and concluded that the debate has to represent “the depositors who entrust their savings to banks, the firms that are financed by banks and society at large”.

The public reading turned this into a warning against deregulation; the trade publication Central Banking ran the headline “Deregulation weakens resilience” the next day. The word does not appear in the speech. Claudia Buch talks of “weaker standards” and of how the capital stack could be “simplified”, and her speech is less an objection to simplification than a proposal about who should test it. In its 17 July 2026 Communication on the competitiveness of the banking sector, the Commission announced that it would keep a closer eye on supervision itself, through “more forceful monitoring by the Commission” and regular reports on the adequacy of capital requirements. Two days before the feedback deadline on that Communication, Claudia Buch put a different set of watchers on the table: academics, savers and taxpayers, equipped with evaluation frameworks and data. What follows places the two offers side by side and re-counts the second consultation round, which Claudia Buch could not yet know on 15 September; it describes the starting position ahead of the legislative package due in the first quarter of 2027, and it does not predict the outcome.

The second round is more lopsided than the first

The figure Claudia Buch cites comes from a Commission staff working document, the summary of consultation responses. The consultation ran from 11 February to 19 April 2026. Responses came from 22 of the 27 Member States and seven non-EU countries, and the breakdown by respondent group exists there only as a pie chart: 43 per cent business associations, 16 per cent banks, 8 per cent other firms, 7 per cent national supervisors and deposit guarantee schemes, 5 per cent governments, 2 per cent EU bodies, 19 per cent everyone else. Belgium and Germany top the list of countries of origin with 15 per cent each, which in Belgium’s case is no surprise, given that most European trade associations are headquartered there. The Commission’s own summary records that the effectiveness of the framework for financial stability was “widely recognised”, while its growing complexity drew “sharp criticism”.

The speech of 15 September could not evaluate the second round, because it was delivered two days before that round closed. Alongside its 17 July Communication, the Commission opened an eight-week feedback period ending on 17 September. The “Have your say” portal lists 121 published submissions, and the respondents’ self-classification is of little use: the association AFME registered as a non-governmental organisation, the Dutch banking association as a trade union, the American Bank Policy Institute as “other”. Classified by organisation name, the picture is sharper than in spring: 85 submissions from the financial industry, ten from the rest of business, eight from public authorities, and 18 from academia, trade unions, non-governmental organisations and citizens. The private sector thus accounts for 78.5 per cent of the submissions, public authorities for 6.6 per cent. These figures come from this article’s own classification of the published list of respondents, not from the Commission, and they carry the imprecision of any classification by name.

Among the eight public authorities are three Polish institutions, the Danish government, the Norwegian finance ministry and the central banks of Latvia, Romania and Czechia; no German, French or EU authority submitted feedback. Of the 121 submissions, 91 arrived on 15 September or later, 54 on the final day alone. That is the pattern of every consultation, and it is also why Claudia Buch does not frame her figure as an accusation: “Each stakeholder offers a different and valuable perspective. But the uneven contribution of the various stakeholders shows the need to better balance the debate.” Those who submit a great deal are not wrong for doing so; they simply have few counterparts.

The Commission intends to watch supervision itself

The Communication “Competitiveness of the Banking Sector and the Single Market in Banking” of 17 July 2026 is the document Claudia Buch refers to when she says that “the ensuing legislative process provides an opportunity to adopt that holistic perspective”. It names three obstacles: fragmentation along national borders, a transposition of the Basel standards that could take better account of European specificities, and undue complexity. Over 23 pages, the Commission makes 38 announcements, among them “clear proposals regarding the output floor”, a “long-term, strategic, EU approach to market-risk capital requirements”, the removal of the Pillar 2 requirement related to the leverage ratio, fewer macroprudential buffers and a simpler calibration of the resolution requirement MREL, the minimum requirement for own funds and eligible liabilities. The Commission states plainly what that implies: “Measures taken to boost competitiveness can be expected to impact the level of capital requirements of banks.” The trade-offs, it adds, call for “a combination of technical expertise and political judgement”.

The section that explains Claudia Buch’s speech sits under the heading “Competitiveness as a shared responsibility”. There, the Commission “should more proactively monitor and ensure adequate balance between risk-taking and financial stability”, supervisors should “avoid a zero risk tolerance culture”, and accountability instruments should be used “to the maximum extent” and, “if ineffective, reinforced”. In concrete terms, the Commission is considering a mandate for the European Banking Authority (EBA) and the European Systemic Risk Board (ESRB) to report regularly on “the adequacy of bank capital requirements across the EU”, and it announces regular discussions with the Single Supervisory Mechanism (SSM) and the Single Resolution Board (SRB) on “the impact of supervisory and resolution actions on the smooth functioning of the internal market”. On the day of publication, Finance Watch, in the words of Julia Symon, its Head of Research and Advocacy, called this “pulling prudential supervision into a political competitiveness agenda”.

This is the passage answered by the sharpest and least quoted sentence of the speech: “Consistency and coordination is, in my view, what a "holistic" view of capital is all about, not the weakening or widening of policy mandates, or the setting of quantitative caps.” That is no rejection of scrutiny but a question about its purpose: Claudia Buch herself asks “who monitors the monitor?” and lists the answers, from the European Parliament to the assessment programme of the International Monetary Fund. Her objection concerns the goal against which supervision is measured. In the same Communication, the Commission calls itself “the primary EU institution responsible for executing the EU’s competitiveness and competition mandate”; supervision measures its actions against the task in Article 1 of the SSM Regulation, “the safety and soundness of credit institutions and the stability of the financial system”. A watcher with a competitiveness mandate tests something different from a watcher with a stability mandate, and Claudia Buch proposes a third that represents neither.

Since July, simplifying also means lowering

Anyone going through the simplification wave of 2026 finds two layers. The first concerns procedure and reporting. On 26 June the ECB discontinued around 40 of some 130 supervisory publications without changing a single legal obligation, as described here. The German Federal Financial Supervisory Authority (BaFin) introduced three size classes with the ninth revision of its MaRisk rules, which runs a third fewer pages. The EBA wants to halve the data points in supervisory reporting, and the Commission echoes that goal in its Communication, stating that the number of data points is expected to be “cut by 50%”. The justification rests on a figure that is five years old: 11.2 billion euros in reporting costs a year for EU banks, estimated by the EBA in 2021. According to the EBA report on national data requests of April 2026, competent authorities made a further 671 structured requests in 2025 covering 978,109 data points; the simplifications decided so far remove 38,425 of them, just under four per cent.

The second layer is capital, and since 17 July it is official. The Commission has postponed the application of the market risk rules from the Fundamental Review of the Trading Book (FRTB) to 1 January 2027 and on 4 June adopted a delegated act softening their effect until the end of 2029; what that means for trading banks is set out elsewhere. On operational risk it overruled its own banking authority. And for 2027 it announces proposals on the output floor, the lower bound which, in the words of its own footnote, “limits the extent to which banks can reduce their capital requirements with internal risk models”. The ECB Governing Council, too, proposed through its simplification task force in December 2025 that the capital buffers be merged into two, one releasable and one fixed; the same report demands that “any proposal to change the EU prudential framework should sustain current levels of resilience”, and it names capital neutrality twice as an open question rather than a promise.

The speech draws the line between the two layers with evidence it did not produce itself. The supporting factors for loans to small and medium-sized enterprises and for infrastructure, a discount of 23.81 per cent under Article 501(1) of the Capital Requirements Regulation (CRR) and of 25 per cent under Article 501a, lower the capital requirement without the EBA having been able to demonstrate any effect on lending. The EBA’s March 2016 report records that “there is no evidence that the SME SF has provided additional stimulus for lending to SMEs compared to large corporates”; the November 2022 report on the infrastructure factor says the data do not suffice for a verdict. Claudia Buch concludes: “the benefit of releasing buffers during a crisis does not imply that permanent reductions in capital requirements during normal times will stimulate credit or growth.” The Basel Committee reached the same result in its evaluation of 14 December 2022, adding that the banks most affected by the reforms saw “a greater reduction in their cost of capital”. This evidence is admittedly older than the debate in which it is cited, and the Bank Policy Institute in Washington has publicly attacked the most recent ECB study on the subject. Yet that is precisely the argument Claudia Buch wants to have, and she wants to have it with studies rather than position papers.

Frankfurt 1999 and London 2026: two regimes for watchers

The speech supplies its own comparison, with a quotation older than the banking union. On 17 June 1999, Ottmar Issing, then Chief Economist of the ECB, gave the speech “The ECB and its watchers” in Frankfurt and said the central bank needed to hear dissent “even more”, “because this is when we learn”. That speech grew into a conference series which the Institute for Monetary and Financial Stability at Goethe University now runs under Volker Wieland; according to the institute, the 26th edition took place on 25 March 2026 with around 400 participants. Banking supervision has no such following, and Claudia Buch says so explicitly: “While there is no direct equivalent to "ECB watchers" in the field of banking regulation and supervision, this conference can serve as a catalyst for change.” That is why the Frankfurt conference of 15 September carries the number one in its name.

The second regime is the British one, and it shows what the alternative the Commission is now building looks like in practice. Section 25 of the Financial Services and Markets Act 2023 obliges the Prudential Regulation Authority, “so far as reasonably possible”, to facilitate the international competitiveness and growth of the UK economy as a statutory secondary objective alongside stability; Section 26 requires annual reports on it. The consequences are on record: the implementation of Basel 3.1 was postponed on 17 January 2025 to 1 January 2027, expressly “taking into account competitiveness and growth considerations”, and in July 2025 the Treasury raised the threshold for resolution requirements. The British model is admittedly exactly what Claudia Buch means by a “widening of policy mandates”. Yet the Governor of the Bank of England, Andrew Bailey, said under that very mandate at Mansion House on 14 July 2026 that “to simply argue for less regulation is unhelpfully reductive”, and described the notion of a fixed quantity of bank capital that only lighter rules could turn into more lending as a throwback to the old “lump of labour fallacy”. Claudia Buch adopts his closing thought almost word for word: effective, proportionate regulation lowers the cost of capital, weak regulation raises it. In the United States, Michelle Bowman, Vice Chair for Supervision at the Federal Reserve, has been rebuilding the Basel III endgame proposal into a “single stack” since March 2026. Three regimes, three kinds of watcher: academia in Frankfurt, statute in London, politics in Washington and Brussels.

Watchers need binoculars, and those are still missing

The speech would have remained an appeal had Claudia Buch not added the third area, the infrastructure. “To engage in birdwatching, you need good binoculars, and a lot of patience,” she said, and watchers of supervision need more: “evaluation frameworks, repositories, access to data and information.” The inventory is sobering. FRAME, the repository of the Bank for International Settlements that collects and standardises quantitative studies on the effects of financial regulation, holds 17 studies with 37 estimates in its capital-and-lending block; by Claudia Buch’s own account, much of the work on capital and lending dates from the years around the financial crisis. In March 2025 the ECB launched a pilot that gives researchers access to anonymised balance sheet data for around 2,000 banks and interest rate data for around 300 banks covering 2007 to 2023. On 28 January 2026 the EBA opened its Pillar 3 data hub, the first platform for the disclosures of every institution in the European Economic Area, and it plans a public register of all European and national data requests to banks for early 2027.

That is more than existed three years ago and less than a watcher needs. A repository of 17 studies does not answer the questions Claudia Buch herself poses: whether capital costs growth, whether risks have migrated elsewhere, whether European rules hold European banks back. Nor do the consultation responses answer them; they assert them. In its April 2026 response, the European Banking Federation writes that gold-plating raises requirements by “up to 66%” above the Basel minimum and puts the capital trapped by solo requirements at around 225 billion euros; the association AFME puts the lending capacity a simplification would release at 2.8 trillion euros. Those are figures from the parties concerned, not estimates by anyone else, and nobody checks them, because the instruments to do so are missing. The think tank Bruegel counters in a working paper of April 2025 that the evidence does not support the assumption that European banks are more strictly regulated overall than American ones: “a direct comparison suggests rather the opposite”. Compliance costs, it adds, could indeed be reduced. Reading both statements makes clear why the head of supervision wants studies rather than position papers.

What a bank can bring to this debate

For an institution, the speech is first of all a note on the calendar. The Commission is summarising the submissions on its Communication for Parliament and Council, and in the first quarter of 2027 it will table a package touching the output floor, Pillar 2, buffers, MREL and reporting at once. Anyone who has submitted only cost arguments by then stands on the loud side of the statistic Claudia Buch presents. That is legitimate, and the speech says so. Yet the head of supervision has also announced which kind of contribution is to carry weight in the next round: the kind backed by evidence. A bank that does not merely assert its reporting costs but calculates them by the method of the 2021 EBA study, or that demonstrates the lending effect of a supporting factor from its own portfolio, supplies exactly the evidence the repository lacks.

Secondly, the addressee shifts. Until now an association wrote to the Commission, and the Commission wrote laws. If the Commission in future demands regular reports from the EBA and the ESRB on the adequacy of capital requirements and talks to the SSM and the SRB itself about the effects of supervision, a second addressee appears, and that is the readership of those reports. A board that tests its own capital planning against the ECB’s Pillar 2 methodology, revised since the 2026 cycle of the Supervisory Review and Evaluation Process (SREP), should know that those numbers will not only justify supervision but also occupy its watchers in future.

Thirdly, the 19 per cent deserve a look. The academics Claudia Buch wants to win as watchers work with the data the ECB and the EBA have been releasing since 2025. A bank that supports research with access to its own data buys itself no rule, but it puts a number into the world that a study can test rather than an association assert. Perhaps the Frankfurt conference will remain an academic event, and the community of watchers it wants to found will remain a “relatively rare species”, as Claudia Buch called her watchers. Then the Commission would have the field to itself, with its competitiveness mandate and its conversations with supervisors. The 15 September speech is an attempt to prevent exactly that, without once using the word deregulation.

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