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ORCID

Anna Dobrzańska: 0000-0002-8243-9716

Keywords

bank resolution, Loss-Absorbing Capacity, recapitalisation, MREL, TLAC, simplification

Abstract

The current European Union (EU) framework for bank loss-absorbing capacity rests on two parallel requirements: Minimum Requirement for Own Funds and Eligible Liabilities (MREL) and Total Loss-Absorbing Capacity (TLAC). This creates complex and overlapping requirements. Furthermore, the adopted bank-specific approach to MREL calibration results in complexity, variability, and insufficient predictability of requirements. The aim of this article is to provide a new streamlined and simplified approach under the three-tiered Regulatory Resolution Requirement (RRR) which could replace the MREL/TLAC framework in the EU. The main idea behind the proposal is to adjust the requirement taking into account bank size and systemic impact. Accordingly, for the three bank categories already defined in the EU regulations, we propose a Regulatory Resolution Requirement, along with subordination requirement. RRR aims at simplification and clarification of bank loss absorption and recapitalisation requirement. Such a simplified approach would provide greater predictability and pose less of a regulatory burden while respecting the proportionality principle. The proposal fills a literature gap and aligns with ongoing EU policy discussions on simplification without compromising the restrictiveness of the current requirements.

Acknowledgments

All opinions expressed in this article belong to the author and do not represent the official stance of the institution in which she is employed. 

Funding

The research received no funds.

Declaration of Conflicting Interests

The author declares no potential conflicts of interest with respect to the research, authorship and publication of the article.

Declaration about the scope of AI utilization

The author did not use an AI tool in the preparation of the article.

First Page

79

Last Page

95

Page Count

17

Received Date

07.01.2026

Revised Date

06.05.2026

Accept Date

23.06.2026

Online Available Date

16.07.2026

DOI

10.7172/2353-6845.jbfe.2026.1.6

JEL Code

G01,G21,G18, G28

Publisher

University of Warsaw

Included in

Finance Commons

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