Deposit guarantee: the politics is settled, now the technology reaches into customer data

On 23 July 2026, eight weeks ago, the European Banking Authority (EBA) opened four consultations on deposit protection in a single day: implementing technical standards on depositor information and on the exchange of information between institutions and guarantee schemes, regulatory technical standards on client funds held in omnibus accounts, and guidelines on how schemes invest their funds. All four run until 23 October 2026, according to the EBA’s press release, and the joint public hearing takes place next Thursday, 24 September. It is the first of three deliveries through which the authority translates the revised Deposit Guarantee Schemes Directive (DGSD3) into technical rules.

Public debate about deposit protection has for years turned on a different question: whether Europe gets a common deposit insurance scheme, and the Banking Union with it its third pillar. For these four papers that question is beside the point. The distributional issues of the reform were settled on 20 April 2026, when Directive (EU) 2026/804 appeared in the Official Journal; what is now out for consultation is the mechanics. And the mechanics reach the bank through its customer data rather than through its contribution bill: for a scheme to pay out within seven working days from 11 May 2028, the institution has to know beforehand who sits behind every account, and it has to be able to deliver that knowledge within three working days. EUR 100,000 of cover becomes a data requirement.

The distributional questions have been law since April

Directive (EU) 2026/804 of 30 March 2026 amends the Deposit Guarantee Schemes Directive 2014/49/EU and belongs to the crisis management and deposit insurance (CMDI) package the Commission tabled on 18 April 2023. After the trilogue agreement of 25 June 2025, footnote 2 of the directive records the Council’s first-reading position on 5 March 2026 and Parliament’s on 26 March; the act was signed on 30 March and published on 20 April. Under Article 4 it has been in force since 10 May 2026; under Article 3(1) it applies from 11 May 2028, with the provisions on preventive measures following a year later.

What was politically contested is now fixed. Scheme funds may in future be used in resolution, even where an institution has built up too few bail-in-able liabilities; the Council described that bridge, in its statement on the agreement, as “a last resort” under “strict safeguards”. A harmonised least-cost test under the new Article 11e caps every use, according to the Council at the amount of covered deposits held by the bank in question. And the package keeps the super-preference of covered deposits in insolvency, that is, their ranking ahead of all other unsecured claims, which the German Banking Industry Committee expressly welcomed on 26 March 2026. For the bank as contributor, the question of what its money may be used for is therefore answered. What remains open is how quickly it can make that money reachable when it matters.

For the depositor, little changes at the core. Cover stays at EUR 100,000, which recital 9 names as the fixed reference. A European minimum for temporary high balances is new: under Article 6(2) they are protected for six months at no less than EUR 500,000, where previously protection ran for between three and twelve months with no EU-wide minimum. The payout deadline of seven working days under Article 8(1) stays, and any extension is capped by Article 8(3) at 20 working days from receipt of complete documentation.

Twelve mandates, three deliveries, and a tally that belongs to the EBA

According to its roadmap of 29 June 2026, the directive confers eleven mandates on the EBA, with a twelfth coming from the resolution directive. The authority intends to work through them in three deliveries: four by May 2027, three by May 2028, five by May 2029. For three of the four standards in the first block the directive itself sets 11 May 2027 as the date for submission to the Commission; the client funds standard, the consultation paper says, is planned for submission in the fourth quarter of 2026.

The EBA attaches to the reform a promise of its own making. The directive, the press release of 23 July says, incorporates “over 100 operational improvements, many based on EBA recommendations issued between 2019 and 2021”; the roadmap names five of the authority’s own opinions to the Commission as the source. The phrase appears nowhere in the directive, so the count is the EBA’s. It does, admittedly, reveal who holds the pen: the authority is consulting on rules it proposed half a decade earlier. The direction of the four papers is therefore hardly negotiable; their deadlines, templates and thresholds are.

Three working days decide seven

The implementing standard on information exchange (EBA/CP/2026/14) is the paper that touches the bank most directly. Under Article 16a(7) of the directive it governs the procedures, templates and content of the data an institution delivers to its guarantee scheme, and the reports the schemes send to the EBA. The core sits in the draft’s executive summary: the scheme sets the institution a deadline for the requested data, and that deadline may not exceed three working days from receipt of the request. The directive’s seven working days are thus the scheme’s deadline to the depositor; the bank gets three of them.

What has to be delivered in those three days is the single customer view: for every depositor, all deposits held with the institution, aggregated up to the coverage level, with flags for the cases that depart from the ordinary payout. The draft requires indicators for, among other things, client funds accounts, disputed claims and dormant accounts. Every institution knows the format, admittedly. Yet a three-working-day deadline that applies across Europe turns a file produced on request into one that has to be deliverable at any time. The data model stays; the mode of operation changes.

The standard’s second strand is the schemes’ own reporting: under the new Article 16a(3), which the draft cites, they will report covered deposits, available financial means and the use of funds as at 31 December of the previous year to the EBA by 31 March each year. The figures published on 30 June still rest on the existing data collection under Article 10(10) of the 2014 directive; only the new report will also show what scheme funds were used for. It spares the bank no line of data. It only shows the bank where its numbers end up.

Behind the omnibus account sits a customer the bank has never met

The new Article 8b protects client funds that payment institutions, e-money institutions and investment firms hold for their customers in accounts at a bank, on three conditions: the funds sit in segregated accounts under the safeguarding rules, they are held for eligible clients, and those clients are “identified or identifiable” before the date of determination. Cover then applies per end client, and under Article 8b(2) without aggregation with that client’s other deposits at the same institution. The regulatory standard (EBA/CP/2026/15) is meant, in the words of the press release, to ensure that schemes receive the data needed to identify and reimburse those clients, and to prevent duplicate payouts to the same beneficiary. Providers of crypto-asset services do not appear in the draft.

For the bank that runs the omnibus account, this is a reversal. Whether the end client behind a trust account was protected used to hinge on the phrase “absolutely entitled” in Article 7(3) of the 2014 directive, and so on national law; the EBA found in its opinion of 8 August 2019 that this was unclear in more than a third of member states, and half the respondents to that consultation, according to a Freshfields note of July 2021, opposed protecting client funds at all. That objection can still be made today: the bank pays contributions on balances whose beneficiaries it has never seen, and it carries the cost of identifying them when the time comes. Yet the directive has decided the question, and the standard now governs only how the data flows. A bank running omnibus accounts for neobrokers, payment providers or e-money houses should therefore know which of them meet the three conditions and who supplies the client list when it is needed. The account holder knows. The bank has to be able to ask.

The information sheet gets a corporate design and five mandatory triggers

The second implementing standard (EBA/CP/2026/13) replaces the model information sheet that used to sit in Annex I of the directive; Article 1(20) of the amending directive deletes the annex, and the model moves under Article 16(9) into the standard. The most conspicuous change is a permission: institutions may, the draft says, use “their own visual identity”, “as long as the content, the order of the content, and relative sizes of fonts remain unchanged”. The EBA concedes in the same paper that the sheets will in future look different from one institution to the next. Depositors lose some comparability; banks gain a better chance that their sheet is actually read.

Five triggers come on top, for which paragraph 23 of the draft prescribes mandatory communication with depositors: client funds, the suspension of a payout, the determination that deposits have become unavailable, mergers and acquisitions, and withdrawal from a guarantee scheme. The information sheet thereby becomes a document with versions, triggers and an approval process that checks the order of its content against the standard. Freedom in design is freedom under supervision.

The funds have reached their target; the data chain has not

Financially, the schemes stand where the 2014 directive wanted them. According to the data the EBA published on 30 June 2026 for the reference date of 31 December 2025, the schemes of the European Economic Area hold EUR 85bn, accumulated, in the press release’s words, “over an 11-year build-up through bank contributions”, against covered deposits of EUR 9.1tn. From the published file a coverage ratio of 0.94 per cent follows, calculated as EUR 84.95bn divided by EUR 9,063bn. That ratio is derived here from the raw data; the authority does not publish it, and it covers the whole Economic Area; the EU alone, at EUR 82.5bn and EUR 8.9tn, sits just below it. The statutory target of 0.8 per cent, due by 3 July 2024, has according to the EBA been reached or exceeded by 32 of the 33 EU schemes; one sits below it after a recent payout, and the authority does not say which.

Germany accounts for a quarter of that stock: the three German schemes, the compensation scheme of the private banks, the savings banks’ protection scheme and the cooperative banks’ institutional protection, together cover EUR 2,315bn of deposits according to the EBA file, a quarter of the Economic Area (25.5 per cent, own calculation), with funds of EUR 18.8bn. The file does not support a verdict on whether any single scheme has met its target, because the EBA measures the target against a reference period and only with qualified means. The guidelines on investment (EBA/CP/2026/12) require diversification, low risk and sufficient liquidity under Article 10(13), and they justify the liquidity with a sentence that anticipates the new use in resolution: funds may be needed “within hours rather than days”. A fund that can pay within hours is of limited use, however, if the client list takes three working days.

Greensill in 2021 showed where the predecessor fell short

The predecessor, Directive 2014/49/EU, had already introduced the EUR 100,000, the seven working days and the 0.8 per cent. What it left to national law was the data side: the deadline by which an institution delivers, the shape of the single customer view, the treatment of client funds. The only large German payout of that era shows where this chafed. On 16 March 2021, according to the press notice of the compensation scheme of the German private banks, BaFin determined the compensation case for Greensill Bank AG, about two weeks after the moratorium of early March; deposits were estimated by tagesschau on 17 March 2021, citing banking sources, at around EUR 3.5bn.

The payout ran across two dates that reports tend to blend. By 5 April 2021, Easter Monday, more than 20,500 depositors had received around EUR 2.7bn, according to manager magazin. By 13 April, the banking association reported through Handelsblatt EUR 2.73bn paid or on its way to more than 21,000 of the roughly 22,000 eligible customers; for the remaining 1,000 or so, the association said, the necessary documents or a reply were still missing. That, four weeks after the determination, is exactly the friction the information exchange standard with its single customer view and the depositor information standard with its mandatory notice on unavailability now set out to standardise across Europe. The cover was there. What was missing was a reply from a thousand customers.

A glance across the Atlantic shows the alternative to a data chain codified in advance. When Silicon Valley Bank and Signature Bank collapsed, the US authorities decided on 12 March 2023 by systemic risk determination to protect uninsured deposits as well; the cost to the deposit insurance fund was put by FDIC chairman Martin J. Gruenberg, in testimony to Congress on 17 May 2023, at USD 18.5bn, of which around USD 15.8bn was attributable to uninsured deposits. The United States decided ad hoc when it mattered; the EU codifies beforehand, right down to the deadline for delivering the data. Both routes cost the banks money. Only the second can be planned for.

The Banking Union’s third pillar gets a new proposal in 2027

The debate about a European deposit insurance scheme continues alongside all this, though no longer in the form it took in 2015. The European Central Bank still called such a scheme (EDIS) “the necessary third pillar to complete the Banking Union” in its opinion of 5 July 2023. In its communication COM(2026) 615 of 17 July 2026 the Commission announced it would “Replace the 2015 EDIS proposal with a new proposal to review and simplify the structure of the deposit insurance framework”, with proposals to follow in the first quarter of 2027. That communication has already been assessed here under the title Banking single market 2027; for the four consultations, all that matters is that a replaced proposal moves none of the data requirements that apply from 2028.

The German associations have shifted over three years from rejection to accompaniment. The German Banking Industry Committee rejected the package on 2 June 2023 “in seiner Gesamtheit”, in its entirety. After the agreement, Heiner Herkenhoff, chief executive of the Association of German Banks, called the compromise on 26 June 2025 “ein Schritt in die richtige Richtung”, a step in the right direction. After the final adoption, Daniel Quinten, board member of the National Association of German Cooperative Banks, urged on 26 March 2026 that the transition periods be used, “insbesondere dort, wo zusätzlicher administrativer Aufwand entsteht”, especially where additional administrative burden arises. On the four papers themselves no association had published a response at editorial close; the deadline is still running. What the implementation will cost institutions in euros, nobody has yet quantified. The burden can be described. It cannot yet be priced.

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