The approach of the German supervisors is bold and represents a paradigm shift. We welcome this discussion, as we have long advocated for such a regime. For many regionally focused savings banks, it would provide tangible relief. Not because of lower capital requirements, but because the complex calculation of risk-weighted assets and the associated reporting, disclosure and procedural obligations would be eliminated. We agree with the regulator that the institutions must remain solidly positioned.

Currently, the rule is: one size fits all. Whether a regionally oriented savings bank or an internationally active large bank – all must comply with the same complex rules. For regionally focused institutions, this is disproportionate. Regulatory efforts should correspond to the actual risk. Instead, they tie up resources that are then unavailable for advisory services and lending – and increase consolidation pressure, which is in the interest of neither the institutions nor their customers. The principle holds: global growth emerges in the regions. And this is precisely where savings banks are strong.

The adjusted leverage ratio must ensure stability, but it must not overcompensate the relief. A sense of proportion is needed: a robust foundation, yes – but without creating new hurdles. What is crucial is a coherent package that fits within the European framework. And in all debates about scale, it should be noted: institutions already supplement prescribed quotas with their own individual safety buffers to manage risks appropriately.

Easing reporting requirements and supervisory stress tests would be a tangible step forward – they are major drivers of effort for credit institutions. A streamlined reporting system follows the logic of a radically simplified rulebook with few strict quotas. National reporting requirements also need to be reviewed. The planned elimination of the million-euro loan reporting requirement is a good example. Relief in this area benefits both institutions and regulators alike.

How many savings banks could benefit depends on the specific design of the criteria. If one refers to the threshold of 10 billion euros in total assets that has been discussed so far, a significant portion of our institutions would be included. The key point is: a small banks regime only works if it is not limited to a few institutions. Otherwise, proportionality risks turning into just window dressing.

We expect that overall interest would be high. However, some institutions will assess whether switching is worthwhile or if they are better off under the current rules. Uncertainties remain, such as how the qualitative criterion „no high interest rate risks“ will be measured, in addition to the level of the leverage ratio. Overall, it depends on the „price tag“ of the complete package. It remains important that the regime is voluntary.

There is a chance. It is an important signal that the German supervisors are making such proposals, as it shows that they understand the situation for regionally focused institutions. Requirements must not be designed in a way that further increases consolidation pressure. Mergers must remain a strategic decision made locally – based on their own strength, not due to regulatory pressure.

At the table should be policymakers, supervisors, and the institutions themselves. What is crucial is that the proposals are aligned at the EU – otherwise, the momentum will fizzle out. Therefore, the European Central Bank, the European Banking Authority, and the member states will play a key role. As the largest financial group in Europe, and with the practical experience of our savings banks, we are happy to contribute constructively to this dialogue.