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Kerstin af Jochnick
Board Member
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What is the outlook for the European banking sector?

Conversation between Kerstin af Jochnick, Member of the Supervisory Board of the ECB, and Chris Hallam, Managing Director at Goldman Sachs, at the Twenty-Eighth Annual European Financials Conference, hosted by Goldman Sachs in Madrid

Madrid, 5 June 2024

You have spoken in the past about how greater confidence has now been achieved in the banking sector through a combination of higher capital levels, a reduction of legacy non-performing assets and a review of banks’ internal models, to name but a few elements. We are now in an era where banks are finally able to return capital to shareholders on a consistent and dependable basis — to what extent do you as the supervisor feel comfortable with how bank payouts are progressing?

I will give a two-part answer to this question. The first part is that, in aggregate terms, the European banking sector remains resilient overall, as proven in recent years by its ability to withstand large and sudden external shocks. This resilience has been gradually built over time, partly due to supervisory initiatives to restore confidence in banks such as the ones you mentioned. Our latest annual assessment of banks’ health, the Supervisory Review and Evaluation Process (SREP), showed that banks under our supervision had solid capital and liquidity positions and were benefiting from a surge in profitability.[1] The results of the stress test which we conducted last year suggested that the banking system could withstand a very severe economic downturn, largely because banks were in better shape going into this exercise than in previous stress tests.[2] And the latest edition of the ECB Financial Stability Review also echoes this sentiment by noting that euro area banks have recently been a source of resilience.[3]

The second part of the answer is that banks tend to distribute more capital when they are more profitable, have higher asset quality and are more liquid. There is also evidence to suggest that there has been some catch-up to compensate for the pandemic years when banks were recommended not to distribute capital to their shareholders.[4]

So if we were to put these two elements together, we could see the recent developments concerning banks’ distributions in a positive light, because they suggest that the banking system as a whole is in a position of relative strength. Profitability has long been the Achilles heel of the European banking sector, so the fact that it has been on the mend in recent years amid the turning of the interest rate cycle should be welcome. And in this environment, banks should be allowed to give a fair return back to their shareholders, thereby also remaining attractive to would-be investors should capitalisation needs arise further down the line. It is often forgotten that, in the absence of the latter, banks would be less likely to sustainably fulfil their critical role of supporting the real economy through the lending channel.

However, while banks are in a robust position overall, we also know that they will continue to face a number of headwinds. The risk landscape for banks has been in flux in recent years due to changes in the macro-financial environment, geopolitical shocks, and challenges related to the green and digital transitions. We expect this to continue to be the case going forward. And overall, as recently stressed by the ECB, risks to economic growth remain tilted to the downside[5].

We think that some deterioration in bank asset quality is to be expected in the future amid a more sluggish economy, while interest rates are still high. Coupled with narrowing interest rate margins, a more subdued pace of lending and higher funding costs, this will negatively affect profitability through higher provisions. Market analysts thus expect bank profitability to exhibit a less dynamic behaviour in the future than it has done over the last couple of years.[6]

Therefore, our message to banks is that their medium-term capital planning needs to take into account adverse scenarios which, while not part of the baseline, are still plausible. Against this backdrop, our supervisors have tailored discussions with our supervised banks to assess their planned dividend distributions and capital trajectories on a case-by-case basis.

Touching on the factors facilitating these capital returns, banks have now by and large returned to earning their cost of equity. However, the effects of the period of higher interest rates have yet to feed fully through to banks’ balance sheets. From a supervisory perspective, which elements do you most focus on when examining the sustainability of these returns, and which factors give you most – and least – confidence?

It is true that the full effects of the period of higher interest rates have yet to filter their way to the financial system, so let me answer your question by distinguishing between the “known knowns” and the “known unknowns”.

Among the known knowns”, all else being equal, a weaker economy is likely to imply challenges to borrowers’ creditworthiness. And such challenges are likely to be compounded by the high interest rate environment, especially in leveraged sectors. Taken together, this suggests that a deterioration in banks’ asset quality through the materialisation of credit and refinancing risks may ultimately affect banks’ financial bottom line. In this regard, the headline non-performing loan (NPL) ratio for the banks we supervise has remained low and relatively stable in recent months. However, once we move past this headline figure, a more nuanced picture appears, as NPL volumes have been picking up from low levels in certain market segments, especially in banks’ consumer credit and commercial real estate portfolios.

From a supervisory perspective, this calls for a strengthening of banks’ risk management frameworks to keep such risks in check, especially for sectors which may be leveraged. We think it is key for banks to manage their distressed debtors and exposures early on. We are asking banks to be proactive in detecting and recognising credit risks in their balance sheet, keeping a close eye on vulnerable sectors, as well as proposing workable solutions to their customers. There are deficiencies in banks’ internal governance frameworks which compound such vulnerabilities by complicating the risk identification process, and which also need to be remedied. And while banks are grappling with these near-term risks, they need to continue their preparations to deal with challenges related to the green and digital transitions, which are bound to affect their business models further down the road.

Turning to the known unknowns”, the main question here concerns the evolution of banks’ net interest margins and in particular the extent to which they may narrow in future. This is important because the surge in bank profitability in recent years has been mainly driven by widening net interest margins, with adjustments in banks’ funding costs tending to lag behind the “mechanical” repricing of their floating-rate loans. It is thus evident that the same forces which were working to widen interest margins so far may now work in the opposite direction. This depends on the precise assumptions made about the future direction of ECB monetary policy, which I would rather not comment on. But abstracting from this question, uncertainties in both the degree of pass-through towards deposit rates at different time horizons and in the customer behaviour towards such products offered by banks could mean that bank funding costs may still rise even when markets expect policy rates to decline.

You’ve highlighted that banks today still show weaknesses in risk controls and internal governance — where do you feel banks have made most progress in this regard, and where is there still ground to cover?

Banks’ weaknesses in this area are often long-standing, for example as regards risk data aggregation and reporting capabilities, which we have been flagging in dedicated letters[7]. However, as banks’ progress towards remediating these weaknesses has often been slow, many of them have continued to score poorly on governance in their annual health check assessments even though their risk profile has improved in other areas. This also explains why, during the latest SREP assessment looking at banks’ health, we issued measures to almost three-quarters of supervised banks to address deficiencies in governance.

The identified deficiencies can be broadly grouped into three categories.[8] First, we have concerns about the effectiveness of management bodies, including in their composition, succession planning, collective suitability and the effectiveness of their oversight role. Second, we have found that management bodies often pay insufficient attention to internal control functions, including risk management, compliance and internal audit functions, which in turn hampers their operational functionality. And third, we continue to see fragmented IT landscapes in many banks. As just mentioned, this leads to banks’ low capacity for aggregating data at group level. This is why, in order to clarify our supervisory expectations in this field, we are in the process of publishing a guide on effective risk data aggregation and risk reporting[9].

These have also been flagged as areas for scrutiny in the supervisory priorities which we have set for the 2024-26 period.[10] Therefore, looking ahead and in order to address these deficiencies, our supervisors will stand ready to use enforcement measures, which can range from issuing qualitative measures with clear remediation deadlines to imposing capital add-ons or periodic penalty payments if deadlines are not met.

It’s been accepted wisdom for some time that higher bank profitability would help improve bank valuations, which would in turn make it easier for them to raise capital should the need arise — improving the resilience of the system. However, we now see valuations which still seem relatively low across a range of metrics, despite higher bank profitability. Does that change how you think about through-cycle ease of access to capital for banks and whether or not a higher minimum capital level is required?

The valuations of European banks have improved in recent months, but it is true that, in spite of the surge in profitability in recent years, the aggregate price-to-book ratio remains below one and that valuations often remain below those of international banking peers in non-EU jurisdictions. The conventional wisdom to explain this disconnect is that investors have lingering concerns about banks’ ability to sustain their robust profitability performance. So if this is indeed the case, the question is what is driving this perception and, relatedly, what could be done about it.

Concerning the root causes, there are cyclical, structural and regulatory factors. On the cyclical side, I have already mentioned the headwinds that banks will face, which are likely to impinge on their profitability, including weaker asset quality, higher provisions, a higher cost of funding and lower lending volumes. As regards structural issues, comparisons between valuations of banks in Europe and those in other jurisdictions may partly reflect differences in macroeconomic variables such as growth potential. And closer to the banking industry, several policymakers, including at the ECB, have pointed to overcapacity in parts of the banking sector as a factor weighing down on profitability.[11] In addition, regulatory aspects are also likely to be playing a role. Work done for the ECB Financial Stability Review suggests that the valuations of European banks cannot be explained by fundamentals alone. This points to the influence of bank levies, or “windfall taxes”, which have been introduced by several European countries, as a contributing to market pessimism about shareholder access to returns earned by banks.[12]

Sustained efforts across these different areas would thus be required to assuage market anxieties on the sustainability of the trends in European banks’ profitability. You asked me whether an increase in banks’ capital across the board would be needed to facilitate their access to capital through the cycle in the presence of subdued valuations; I don’t think that this is the case. As I noted at the beginning of our conversation, banks have proven resilient to large and sudden external shocks in recent years, and this is partly because the capital bar which they currently face is now higher than it was when the ECB assumed its supervisory duties almost ten years ago. And as you also mentioned earlier in one of your questions, many banks have now returned to earning their cost of equity.

I thus think that the path towards durably higher valuations of European banks needs to be a more tailored one, requiring action by both bankers and policymakers.

First, banks need to keep working to adapt their business models to the evolving realities of the banking business, above and beyond the favourable tailwind for profitability posed by higher interest rates amid monetary policy normalisation. There is evidence to suggest that a track record of strong profitability and a low cost-to-income ratio are important determinants of higher price-to-book ratios at individual bank level.[13] In order to support banks in their adaption efforts, we have recently unveiled plans to make our supervision more efficient and effective, notably through a reform of the way we conduct our annual assessments of banks’ health through the SREP.[14]

Second, progress to achieve a more integrated and efficient banking market in the banking union as a whole should also support bank valuations through increased profitability. Completing the banking union as originally envisaged through a common deposit insurance scheme, advancing towards a capital markets union, and working towards greater legal harmonisation in those aspects that are important for banking activity stand out as key elements in this regard.

Third, concerning regulatory factors, we view with concern the potential for levies on banks to become permanently entrenched. This is because such taxes lead to an unlevel playing field in the banking market, affect investors’ perceptions on shareholder access to banks’ returns, and have the potential to negatively affect bank lending to the real economy.

You’ve seen increased consolidation or M&A proposals within the European banking sector. From a supervisory perspective, do you find this encouraging as it may create a stronger and more unified banking system? And how dependent do you think further M&A is on the completion of the banking union via a common deposit insurance scheme?

We have seen a fair amount of banking consolidation within national boundaries in recent years – in certain jurisdictions less than in others. But what we have seen relatively little of is consolidation of the cross-border kind[15]. And we would have liked to see more of this type of transactions, because cross-border mergers can help banks diversify both risks and revenues while supporting financial market integration, which is an important objective for the banking union as a whole. Bank mergers in general can also be a means of addressing issues in certain market segments or jurisdictions, such as low profitability and overcapacity. But in the end, this is a call the markets need to make. We see bank consolidation as being a market-led process, whether within national boundaries or at cross-border level. What we have tried to do at the ECB is clarify our supervisory approach to bank mergers within the current regulatory framework, for example as regards capital requirements for the combined entity or the recognition of badwill.[16] These are important aspects in such transactions.

Cross-border mergers have been more the exception than the rule. It is thus fair to say that the number of such transactions has fallen short of the expectations which one may have reasonably have had in a context of a monetary union and a single bank supervisor. And I think that has largely to do with legal fragmentation issues and other structural factors which make cross-border mergers less attractive for banking groups than would otherwise be the case.

Banks looking to expand beyond their national borders now have to deal with an array of different regulations across countries, in securities markets as well as in tax, accounting and insolvency regimes. So increased harmonisation on these fronts would seem to be a necessary condition for fostering cross-border bank integration. And beyond legal differences, there are structural issues, relating to the fungibility of capital and liquidity across countries, which are also deterring cross-border mergers. Capital waivers are not an option under current EU legislation in a cross-border sense, so banking groups cannot freely move capital across their subsidiaries in multiple jurisdictions. Cross-border liquidity waivers are provided for under EU law, and we have tried to create an environment in which banks can use the limited space in the legislation provided to this end.[17] But the take-up of this initiative has been lukewarm, because some host country authorities still fear that local subsidiaries could be put at a disadvantage relative to their parent companies if those parent banking groups got into distress. And in this case, the lack of progress on the third pillar of the banking union, namely a common insurance scheme for bank deposits, appears to be a key hindering factor.

So it is safe to say that if such a common deposit scheme were in place, some national authorities would be less resistant to allowing the free movement of capital and liquidity across borders than they are now, and banks would have greater appetite for cross-border mergers.

Looking next at regulatory capital, how important is the full and faithful implementation of the Basel III standards and where do you see outstanding risks in this regard?

At the ECB, we see the timely, full and faithful implementation of the Basel III reforms in the EU as being very important. At the beginning of our conversation, I hinted that, in my view, the ECB deserved some credit for bringing the banking system to a higher common supervisory standard. But it is important to recognise that this higher supervisory standard was made possible by overhauling the Basel framework after the great financial crisis. I think that the large external shocks which have hit the banking system in recent years have put the revised Basel framework to a significant test. And I believe that we can be pretty satisfied with the outcome thus far in that the framework has worked largely as intended. So overall, my conclusion is that the revised Basel framework has proven its worth – which is why I find it crucial that the remaining Basel III standards be fully integrated into European law.

We are pleased that the legislative approval process by the EU co-legislators has been on track so that the new Basel rules will start applying from January 2025 as envisaged. The ECB stands ready to do its part in implementating the process, notably by contributing to the European Banking Authority’s work on developing the required technical standards and guidelines.

You recently highlighted that the process for unviable banks exiting the market could be improved. How do you envisage improving the resolution of banks and ensuring local authorities follow the designated rulebook?

Indeed, our experience with crisis management in recent years suggests that the process for banks exiting the market in a smooth and orderly manner could be improved in a number of ways. The scope of resolution can be expanded to ensure that the failure of small and medium-sized banks can be addressed in a harmonised manner, and deposit guarantee schemes can be empowered to provide a wider range of crisis management options for addressing potential, or actual, bank failures.

Last year, the European Commission made a number of proposals to improve the European crisis management framework[18] and we at the ECB think that such proposals are definitely going in the right direction.[19] Specifically, we think that such proposals would allow stakeholders to effectively deal with the failure of mid-sized and small banks in a more harmonised manner, while at the same time preserving financial stability, protecting depositors and saving taxpayers’ money. And in this way, it can help to lay the ground for a common European deposit insurance scheme, or EDIS.

For concrete improvements to the existing framework, we support facilitating the use of resolution tools across a broader spectrum of banks. This would enhance the level playing field across banks located in different jurisdictions. Still, broadening the scope of resolution to include small and medium-sized deposit-based banks can only be credible if realistic solutions are found to fund the resolution of these banks in all scenarios. Losses from bank failures must be borne first and foremost by the bank’s shareholders and creditors. At the same time, the framework should allow for the available industry-funded safety nets to be used effectively when needed to protect financial stability.

We therefore think that deposit guarantee schemes should be able to support the use of crisis management tools, for instance by allowing the schemes to contribute to meeting the bail-in conditions for accessing the Single Resolution Fund. Smaller banks often rely heavily on deposits as a funding source and, depending on local market conditions, may have difficulties with issuing financial instruments which could be bailed in if the bank fails. A more flexible system with adequate safeguards would help to reduce the overall costs of crisis. This could be achieved by clarifying and broadening the least cost test and introducing a general depositor preference based on an equal ranking of all deposits. When the deposit guarantee scheme supports the resolution of a bank – e.g., for example by helping to finance a transfer to another bank − it avoids having to pay out all covered depositors, which it would have to do if the bank was liquidated. By supporting a resolution, the deposit guarantee scheme usually needs to mobilise much fewer resources than in a liquidation; this enhances depositor protection, while avoiding contagion risks.

Commercial real estate has been a key focus area over the last year or so, but the impact on European banks has been considerably lower than many market participants originally feared. To what extent do you attribute this to banks’ better management of their loan books and have any supervisory lessons been learned?

I mentioned earlier that the potential materialisation of credit risk in bank’s balance sheets would be a point of supervisory attention for us in the near term. And within the overall credit risk picture, developments in certain markets warrant particular attention from a supervisory point of view. One of them is real estate, because price corrections in this segment have been a major headache for banks in past crises and, through the banking sector, a source of contagion to the real economy too.

Residential real estate and commercial real estate markets are both in a downturn, with borrowers facing higher debt servicing costs due to higher interest rates. It is worth noting that, in aggregate terms, euro area banks’ exposures to such markets differ significantly. While residential mortgages account for almost 30% of euro area banks’ total loans, only around 10% of total bank loans are exposed to commercial real estate.[20] But whereas mortgage borrowers’ debt servicing capacity has been supported by relatively robust labour markets to date, commercial real estate borrowers have faced declining profitability, with higher interest rates reducing the income of specialised firms operating in this market and the value of their properties. The commercial real estate market is also adjusting to lower demand on account of structural changes that were reinforced by the pandemic, notably shifts towards online shopping and working from home. This means that firms and agents operating in this sector are facing challenges on both the financing and income side – an aspect that was echoed in the European Systemic Risk Board’s recommendation last year on vulnerabilities in the commercial real estate sector.[21]

Taken together, these factors suggest that portfolios in the commercial real estate market segment have a higher likelihood of facing debt servicing challenges than those in other market segments. In the current cycle, borrowers in this sector are facing increased refinancing risk, particularly for bullet or balloon loans, which have a large balance that will fall due at maturity. This is a development that we, as supervisors, are monitoring closely, because banks could be exposed either directly, via the credit channel (through loans for construction and purchasing commercial real estate), or indirectly, via the collateral channel (through borrowers using commercial real estate as collateral). We are engaging closely with those banks under our supervision that are most exposed to this risk to ensure that they manage it appropriately.

Thinking next about the green transition − while this has increasingly become a focus topic both for politicians and the investment community, you have highlighted that banks still have some way to go in terms of incorporating climate-related and environmental risks into their risk management frameworks. Can you discuss some of the supervisory actions you’ve taken to ensure improvements here?

There is growing recognition among the global supervisory community that climate-related and environmental risks, or C&E risks for short, may be material for the financial sector. This is why the Basel Committee for Banking Supervision has taken concrete steps to incorporate such risks into the Basel framework.

On our side, assessing banks’ preparedness to deal with climate-related and environmental risks has been a very important workstream for us in recent years, as reflected in our supervisory priorities. Throughout this process, we have made it clear to banks under our supervision that it is not up to the ECB to tell them how green their lending policies should be. But we have also underlined that, in our view, failing to adequately manage C&E risks is no longer compatible with sound risk management. And this is why we expect them to manage C&E risks in the future in the same way as they manage any other material risk today.

We have taken a number of initiatives in recent years to promote banks’ awareness on this matter, such as publishing a guide on our expectations for banks’ management and disclosure of C&E risks[22], conducting a climate risk stress test[23] and carrying out a thematic review to assess banks’ ability to identify and manage such risks[24]. The good news is that, following these efforts, our supervised banks now have a broad awareness of the relevance of C&E risks. For example, over 80% of euro area banks have already concluded that transition risks have a material impact on their strategies and risk profiles.[25] However, as outlined in your question, these initiatives have also shown that while banks have made progress in their treatment of these risks, they still have some way to go to properly incorporate them into their risk management frameworks.

This is why we set intermediate and bank-specific deadlines for aligning frameworks with our supervisory expectations in this area by the end of 2024. Some banks did not comply with our first intermediate deadline of March 2023, which focused on the materiality assessment of the impact of C&E risks on banking activities. We responded by issuing binding decisions that impose periodic penalty payments if the affected banks fail to comply with the requirements by a certain date. We will be taking a similar approach to the rest of our implementation deadlines. Our supervisory efforts in this area will also be helped by the fact that EU legislation will soon stipulate that banks should have mandatory transition plans, because this legal proviso will also mandate supervisors to check such plans and assess banks’ progress in addressing their C&E risks.

Lastly, looking at digitalisation, how do you assess the progress banks are making in their digital transformation, in terms of a more effective customer experience as well as cybersecurity and operational resilience?

There is no doubt that banks are becoming increasingly digital. For example, 60% of banks under our supervision are already using artificial intelligence (AI). The use of AI in banking can bring advantages for banks, for example by facilitating online customer transactions, streamlining processes and providing automated suggestions to customers based on their preferences. But the growing use of this technology evidently also involves a number of risks, in addition to the risks to operational resilience from outsourcing as well as cyber risks.

From a supervisory point of view, we want to ensure that banks are in a good position to manage risks stemming from the digital transformation, including implications for the sustainability of their business models. The results of the digital transformation survey we conducted last year paint a mixed picture in this regard.[26] While almost all banks have a digital transformation strategy, their degree of maturity differs. And while banks spend on average a fifth of their IT budget on digitalisation, most of them do not yet have a dedicated budget for digital transformation.

So one of our supervisory priorities in future will be to foster banks’ further progress in digital transformation and build robust operational resilience frameworks. The former includes an expectation for banks to develop and execute sound digital transformation plans through adequate arrangements, for example regarding business strategy and risk management, in order to strengthen their business model sustainability and mitigate risks related to the use of innovative technologies. We will also publish our supervisory expectations on banks’ digital transformation, which will help strengthen the supervisory assessment methodology in this area.

Digitalisation also affects the operational resilience frameworks of banks, for one because they increasingly depend on a few third-party service providers. Let me highlight two aspects. First, we have recently launched a public consultation on our guide on outsourcing cloud services.[27] The guide aims to clarify the ECB’s understanding of legal requirements in this area and explain its expectations for the banks it supervises, drawing on risks and best practices observed in the context of ongoing supervision by our Joint Supervisory Teams as well as dedicated on-site inspections. And second, we have noticed an increase in the number of cyber incidents reported to supervisors in recent months. We will be unveiling the results of a system-wide cyber resilience stress test later this year.

  1. European Central Bank (2023), ECB keeps capital requirements steady in 2024, refocuses supervisory priorities, 19 December.

  2. European Central Bank (2023), 2023 stress test of euro area banks – final results, July.

  3. European Central Bank (2024), Financial Stability Review, May.

  4. European Central Bank (2023), Economic Bulletin, Issue 6.

  5. European Central Bank (2024), Monetary policy statement, April.

  6. European Central Bank (2024), Financial Stability Review, May.

  7. European Central Bank, Letters to banks.

  8. European Central Bank (2023), SREP 2023 aggregate results, December.

  9. European Central Bank (2023), Guide on effective risk data aggregation and risk reporting, July.

  10. Enria, A. (2023), Introductory statement at the press conference on the 2023 SREP results and the supervisory priorities for 2024-26, 19 December.

  11. See for example Draghi, M. (2016), Welcome address at the first annual conference of the European Systemic Risk Board,September; European Parliament (2017), “Overcapacities in the European Banking Sector”, July; and Gardo, S. and Klaus, B. (2019), Overcapacities in banking: measurements, trends and determinants, ECB Occasional Paper Series, No 236, November.

  12. European Central Bank (2023), Financial Stability Review, November.

  13. European Central Bank (2023), Financial Stability Review, November.

  14. Buch, C. (2024),Reforming the SREP: an important milestone towards more efficient and effective supervision in a new risk environment”, The Supervision Blog, 28 May.

  15. European Central Bank (2022), Biannual Report on Financial Integration

  16. European Central Bank (2021), Guide on the supervisory approach to consolidation in the banking sector, January.

  17. Enria, A. and Fernandez-Bollo, E. (2020), “Fostering the cross-border integration of banking groups in the banking union”, The Supervision Blog, 9 October.

  18. European Commission (2023), Banking Union: Commission proposes reform of bank crisis management and deposit insurance framework, press release, 18 April.

  19. European Central Bank (2023), Opinion of the European Central Bank of 5 July 2023 on amendments to the Union crisis management and deposit insurance framework, 5 July.

  20. European Central Bank (2023), Financial Stability Review, November.

  21. European Systemic Risk Board (2023), ESRB issues a recommendation on vulnerabilities in the commercial real estate sector in the European Economic Area, 25 January.

  22. European Central Bank (2020), Guide on climate-related and environmental risks, November.

  23. European Central Bank (2022), Climate risk stress test, July.

  24. European Central Bank (2022),”Walking the talk: banks gearing up to manage risks from climate change and environmental degradation. Results of the 2022 thematic review on climate-related and environmental risks”, November.

  25. Elderson, F. (2024), “’Failing to plan is planning to fail’ – why transition planning is essential for banks”, The Supervision Blog, 23 January.

  26. European Central Bank (2023), Takeaways from the horizontal assessment of the survey on digital transformation and the use of fintech, l5 February.

  27. European Central Bank (2024), ECB consults on outsourcing cloud services, 3 June.


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