Frequently asked questions

...on the calculation of the supervisory fee and the fee debtor contact details

How do I nominate the fee debtor?

All fee-paying institutions that are part of a supervised group nominate a single entity to act as the fee debtor on behalf of the whole group. This is done by sending the ECB a signed notification by post or email. The closing date for submitting a new fee debtor nomination is 30 September each year in order to ensure a smooth feeing process.

Fee debtor notification form

How can I provide our fee debtor contact details?

The annual deadline for updating fee debtor details is 30 September. Fee debtors who have previously provided their contact details are only obliged to provide an update if there are changes. Please read the data protection statement.

Please only provide contact details via the ECB’s online portal. ECB staff members do not have access to the accounts of individual banks in the portal, so they are unable to do this on a bank’s behalf. The ECB recommends that an email address be provided that relates to a department or group rather than to an individual staff member in order to ensure that internal staff changes do not affect the ECB’s communication with fee debtors.

If you have not yet received your user ID and password or wish to change the name of the fee debtor, please contact the fees team, preferably by email at SSM-fee-enquiries@ecb.europa.eu.

Data protection statement

Do I need to provide my updated contact details to the ECB if I have already provided them to the Single Resolution Board (SRB)?

Yes, fee debtors are obliged to communicate any changes to their contact details to the ECB by 30 September of each fee period.

My banking group structure has changed since I submitted my fee debtor notification form. What should I do? Do I have to submit the form every year by 30 September?

If the changes in your group structure affect the head of the group or the subsidiary which was the previously nominated fee debtor, you should notify the ECB by submitting a new fee debtor notification form. Other changes within the group do not require a new fee debtor notification form.

Fee debtors have to submit their form by 30 September of each year in order to ensure a smooth feeing process.

Do I need to report any change in my bank’s situation, for instance mergers, absorption or de-authorisation? What should I do if a change is not reflected in the supervisory fee notice I have received?

A change in your situation may have an impact on the calculation of the annual supervisory fee. Please notify the fees team via email about any changes in your bank’s situation. They will get back to you with information on how to proceed in your particular case.

We are a newly authorised standalone bank. How should we proceed with regard to the ECB supervisory fees?

A newly authorised bank that is located in a participating Member State and does not form part of an existing supervised group must pay the annual supervisory fee. The amount is calculated on the basis of the number of full months for which the bank has been supervised in the fee period.

Please provide the ECB with the contact details of the person or, preferably, the department responsible – in particular their email address – and the ECB will inform you about the next steps.

SSM-fee-enquiries@ecb.europa.eu

The supervisory status of my bank changed from less significant to significant following an acquisition by a significant banking group. Will that affect my supervisory fee?

If your bank was a stand-alone, less significant institution prior to the acquisition by a significant supervised group, there could be an impact on your supervisory fee. In general, following an acquisition, the annual supervisory fee will be calculated on the basis of the number of full months for which the supervised entity was a stand-alone less significant institution (Article 7(1) of the ECB Regulation on supervisory fees).

The fee calculation is performed at the highest level of consolidation within participating Member States. Therefore, when credit institutions are part of a supervised group established in the participating Member States, a single fee is calculated and levied at group level.

Please notify the fees team via email about any changes in your bank’s situation. They will assess your case and get back to you with information on how to proceed in your particular case.

...on how to submit fee factors

Who has to submit the fee factors?

The ECB is responsible for the effective and consistent functioning of the Single Supervisory Mechanism in its entirety, i.e. for both the significant banks that it directly supervises and the less significant banks that it indirectly supervises. All supervised banks are therefore obliged to pay a supervisory fee.

The annual supervisory fee is calculated at the highest level of consolidation for all banks supervised by the ECB based on fee factors as at the reference date of 31 December of the preceding fee period, or the applicable reference date as explained in the examples below.

From the 2020 fee period onwards, the ECB will reuse FINREP and COREP data to determine the fee factors for the majority of supervised banks.

Two categories of banks must still provide their fee factors via a separate collection process: (i) groups that exclude assets and/or risk exposure amounts of subsidiaries in non-participating Member States; and (ii) branches established in participating Member States by credit institutions from non-participating Member States which are not subject to the ECB’s FINREP Regulation.

When should I submit data regarding the fee factors and to whom?

Fee debtors that still have to provide fee factors should submit the information on the fee factors to national supervisory authorities using the templates contained in the annexes to the ECB Decision on fee factors.

The fee factors should be submitted by close of business on 11 November of the current year, or the next business day if 11 November is not a business day, with a reference date of 31 December of the preceding year or as applicable, please see example below. The fee notices will be issued in the first six months of the year following the fee period.

How should I submit the fee factors?

The fee factors should be submitted to the national supervisory authorities using the templates in the annexes to the ECB Decision on fee factors. These templates should be completed in accordance with the instructions provided, which also includes information on audit certification and management sign-off and when these are required.

Must a supervised group exclude the assets of subsidiaries established in non-participating Member States and countries outside the EU?

No. Although the Regulation on supervisory fees does provide the option to exclude assets of subsidiaries located in non-participating Member States and countries outside the EU, this option is there for the benefit of the supervised groups affected, as it lowers the annual supervisory fees that they would otherwise have to pay. However, if the burden of calculation is greater than the expected reduction in annual supervisory fees, it is more efficient for the supervised group to include such assets.

In order to ensure a smooth collection process, it is necessary to establish which groups with subsidiaries established in non-participating Member States or third countries intend to exclude the related assets and/or risk exposure amounts from their fee factors.

Are the annual supervisory fees levied on all branches established in participating Member States?

No. Annual supervisory fees are only levied on branches established in a participating Member State by a parent bank established in a non-participating Member State. For example, an EU branch in a participating Member State (e.g. Germany) will have to pay the supervisory fee to the ECB if its parent bank is established in a non-participating Member State. The parent bank may be subject to supervision by the relevant national supervisory authority (e.g. in Sweden), and may consequently be charged by that authority. This requirement is independent of the requirement for the EU branch to pay a supervisory fee to the ECB.

In this context, please bear in mind the following:

  • Two or more fee-paying branches established by the same credit institution in a single participating Member State are deemed to be one branch
  • Fee-paying branches of the same credit institution established in different participating Member States (e.g. Belgium and Germany) are not deemed to be one branch
  • For a branch and a subsidiary in the same participating Member State, two different supervisory fees will be levied

Who has to pay?

At what level of consolidation should supervised groups report the fee factors?

Supervised groups operating in one or more participating Member States must submit only one return, using the highest level of consolidation across those participating Member States. One single supervisory fee will be calculated.

Treatment of banking groups

What happens if I don't submit the fee factors in time?

If a fee debtor that still has to provide fee factors fails to provide the fee factors, the ECB will determine the missing fee factors itself on the basis of available information. Not providing fee factors is considered a breach of the ECB Regulation on supervisory fees and may trigger sanctions.

How can I resubmit the values of my fee factors during the comments period?

If you submitted separate fee factors templates via your NCA, you can resubmit the fee factors data using the same format and submission channel during the 15-day comments period. If the ECB determined your fee factors on the basis of COREP and FINREP data and the values of total risk exposure/total assets available in the online portal are outdated, you can resubmit your COREP and FINREP reports during the 15-day comments period via your NCA. It should be noted that FINREP and COREP data may change after the 15-day comments period. However, for feeing purposes, once data have been used for the calculation of the supervisory fee for the fee period, future amendments will not be taken into account and no recalculations of supervisory fees will take place.

What is the ECB Decision on fee factors about?

The ECB Decision on fee factors sets out the methodology and procedures for calculating the two fee factors, i.e. total assets and total risk exposure.

Are branches that are established in participating Member States by credit institutions established in European Economic Area (EEA) countries that are not EU Member States obliged to submit fee factors?

Yes. Branches that are established in participating Member States by credit institutions established in countries of the European Economic Area (EEA) that are not EU Member States, namely Norway, Liechtenstein and Iceland, are supervised by the ECB (indirectly in the case of less significant institutions). Depending on their significance, the direct supervision of these branches is conducted either by the ECB, or by the national competent authority. Thus, they are obliged to report fee factors to the ECB, which will be used to determine their annual supervisory fee.

SSM Framework Regulation

Example: My bank merged with another bank after 1 January 2020. Do I need to submit fee factors with a reference date of 31 December 2019?

No, you do not have to submit fee factors with a reference date of 31 December 2019. However, fee debtors established after 1 January 2020 that fall into one of the two categories required to submit fee factors are required to submit the fee factors to their national competent authority as at the reference date closest to 31 December of the preceding year in order to allow the annual supervisory fees to be calculated. For an entity established on 1 January 2020, the reference date closest to 31 December 2019 would be 31 March 2020. For an entity established on or after 1 April 2020, the reference date closest to 31 December 2019 would be 30 June 2020.The same reference dates will also be used by the ECB to determine the fee factors for entities established on 1 January 2020 that report COREP and FINREP data for prudential purposes.

Example: Our fee-paying branch has ceased its commercial activity and will be closed on 1 April 2020. Do we need to submit fee factors with a reference date of 31 December 2019?

Yes. In accordance with Article 7 of the Regulation on supervisory fees, where a supervised entity is supervised for only part of the fee period, the annual supervisory fee will be calculated by reference to the number of full months of the fee period for which the supervised entity is supervised. As a supervised entity within the 2020 fee period, the fee-paying branch is still obliged to submit fee factors with a reference date of 31 December 2019 in compliance with Article 10(4) of the Regulation on supervisory fees to facilitate the calculation of the supervisory fee payable. A supervisory fee will be determined for the period from January to March 2020.

ECB Regulation on supervisory fees

Example: Our accounting year-end is different from 31 December. Do we need to submit fee factors with a reference date of 31 December 2019?

In accordance with Article 10(3)(bb) of the Regulation on supervisory fees, when a supervised entity prepares annual accounts, including consolidated annual accounts, based on an accounting year which deviates from the calendar year, the reference date for the total assets shall be the accounting year-end corresponding to the preceding fee period. For an entity that was established before 1 January 2020 and has an accounting year-end on 31 March, the reference date for the total assets fee factor shall be 31 March 2019.2019.

ECB Regulation on supervisory fees

Are fee-paying branches expected to provide statistical data when submitting their total assets?

Not necessarily. For branches falling under the scope of the ECB’s FINREP Regulation, the ECB will determine their fee factors on the basis of the total assets reported for prudential purposes. For branches that are obliged to submit fee factors templates, the total assets should correspond to the amount of total assets stipulated in Article 2(12)(b) of the ECB Regulation on supervisory fees. Therefore, a branch of a credit institution which is established in a non-participating Member State should submit to the ECB total assets calculated on the basis of the total value of assets as determined on the basis of the most recent audited annual accounts prepared in accordance with International Financial Reporting Standards (IFRS) as applicable within the Union in accordance with Regulation (EC) No 1606/2002 of the European Parliament and of the Council and, if those annual accounts are not available, the annual accounts prepared in accordance with applicable national accounting laws. For fee-paying branches that do not prepare annual accounts, total assets means the total value of assets as determined in accordance with Article 51(5) of Regulation (EU) No 468/2014 (ECB/2014/17), i.e. statistical data. Branches that report the total value of assets for prudential purposes on a voluntary basis can use this value for determining the total assets fee factor. However, the ECB does not reuse the voluntarily submitted data for the purpose of determining the fee factors and it will still be necessary to submit the fee factors template.

Is auditor verification needed for fee-paying branches?

Not necessarily. In lieu of auditor verification as a means of certification of the total assets of the branch, the manager of the branch or, if the manager is unavailable, the management body of the credit institution establishing the fee-paying branch shall certify the fee-paying branch’s total assets by means of a management letter submitted to the relevant NCA. A template for the management letter is attached.

This exception applies only for fee-paying branches and does not apply to fee debtors who are required to provide auditor verification of their financial statements in line with Article 3.2(b) of the ECB Decision on fee factors.

...on how to pay the supervisory fee

Why have I not received a fee notice?

The ECB issues fee notices electronically via the ECB’s online portal to each fee debtor. The expected date of issuance is in the second quarter of the following fee period. For the 2020 fee period this is in the second quarter of 2021. An automatic email notification about the uploading of the related correspondence (fee notice, reminder or interest letter) will be sent to the email address you provided via the ECB’s online portal.

If you have not received the fee notice by the end of this period, please contact the fees team by email.

SSM-fee-enquiries@ecb.europa.eu

I am missing the payment details, but have received a fee notice (or reminder or interest letter).

The payment details are always stated on the second page of the respective document. If you require additional confirmation of the payment details, please contact the fees team via email.

SSM-fee-enquiries@ecb.europa.eu

I need to know the ECB’s VAT number (tax reference) before I can pay the ECB supervisory fee

The supervisory fee is considered a public charge under Article 13 of the VAT Directive (2006/112/EC), and is consequently VAT exempt. The ECB, as an EU institution, is not required to register for VAT or corporate income tax purposes and therefore does not have any tax identification number.

I have received a notice to pay a supervisory fee to our national supervisory authority. How do we treat it?

The national supervisors play an important role in banking supervision within the Single Supervisory Mechanism.

However, their supervisory costs are not taken into account in the calculation of the supervisory fee paid to the ECB. This means that the national supervisory authorities maintain their right to levy fees in accordance with national law. Any questions related to the national supervisory authority fee should be directed to your national supervisory authority contact point directly.

National supervisors

I have received a fee notice from the Single Resolution Board. What should I do?

The ECB is only responsible for the Single Supervisory Mechanism (not the Single Resolution Mechanism). The ECB and the Single Resolution Board (SRB) are independent institutions. Any questions related to SRB invoicing should be directed to your SRB contact point or to the national resolution authorities directly.

Can I pay my supervisory fee by direct debit?

Yes. In fact the ECB’s recommended payment method is SEPA direct debit. Direct debit ensures that the fee is paid on time and, therefore, avoids possible interest charges for late payments. If you opt for this payment method, you can enter your bank details via the online portal and print out a direct debit mandate. Please sign and send the original to the ECB’s address indicated on the mandate.

What should I do if there is an error in the fee notice?

If there is a potential factual error in the fee notice, or for any other general queries, please contact the fees team.

SSM-fee-enquiries@ecb.europa.eu

This is without prejudice to the fee debtor’s right to submit an appeal against the fee notice to the Administrative Board of Review. All appeals must be submitted within one month of receipt of the fee notice.

Administrative Board of Review

The decisions taken by the ECB in the exercise of its supervisory tasks can also be challenged before the Court of Justice of the EU.

Feedback statement

What happens if I don’t pay by the deadline?

Fees are due within 35 days of the date of issuance of the fee notice.

In the case of partial payment or non-payment of the fees, the ECB is entitled to charge interest on a daily basis on the unpaid amount of the supervisory fee.

Interest is accrued at an annual rate equal to the ECB’s main refinancing rate plus 8 percentage points from the date on which the payment was due until the date preceding the date on which the unpaid amount is credited to the ECB’s bank account.

ECB Regulation on supervisory fees

...on technical issues regarding the online portal

My password for the online portal does not work. What should I do?

You can reset your password by clicking on “Request new password” and entering your username and the already registered email address (this is the email address designated as the preferred email address for communication with your bank and the one to which the ECB sends notifications). Please send an email to SSM-fee-enquiries@ecb.europa.eu if you continue to encounter problems.

I am having difficulties when viewing or editing information via the online portal. What should I do?

The online portal is only compatible with the following internet browsers: Internet Explorer (version 9 or later), Google Chrome and Firefox. If you continue to encounter technical problems despite using one of these browsers, please contact us by email.

SSM-fee-enquiries@ecb.europa.eu

After entering the IBAN for a direct debit, I receive a message that my “bank does not exist”. What should I do?

Please send an email to the fees team containing a screenshot of the error and/or the relevant IBAN. The fees team will add the bank code to the ECB’s system and then ask you to re-enter the IBAN via the online portal.

SSM-fee-enquiries@ecb.europa.eu

I have added more than one email address to the online portal. Are fee notifications sent to all of these email addresses?

No, fee notifications are only sent to the email address you selected as your “preferred” address. Please check the online portal and, if necessary, change your preferences. If you have not received a fee notification, please contact the fees team by email. The ECB recommends that you provide an email address that relates to a department or group rather than to an individual staff member in order to ensure that internal staff changes do not affect our communication with you.

SSM-fee-enquiries@ecb.europa.eu

I would like to use the online portal in my local language but it is only available in English

The ECB’s online portal is currently only available in English. You can display a manual after logging in to the online portal (in the bottom right corner of the screen). It provides you with translations of all online portal screens into all euro area languages.

In addition, any time you are notified by email that a new document has been uploaded to the online portal, you are also provided with a link to a translation.

For the 2020 fee period onwards, fee debtors will be able to choose the language in which they receive the fee notice. The ECB will issue a separate communication to fee debtors to initiate the collection of language preferences in the second half of 2020.

Furthermore, the SEPA core direct debit form is published in all euro area languages on the ECB’s banking supervision website.

If you have any further queries, please contact the ECB’s fees team directly.