Opinion of the European Central Bank of 17 June 2026 on the functioning of a Systemic Stability Council (CON/2026/19)

OPINION OF THE EUROPEAN CENTRAL BANK of 17 June 2026 on the functioning of a Systemic Stability Council (CON/2026/19) Introduction and legal basis

On 11 May 2026 the European Central Bank (ECB) received a request from the Greek Ministry of National Economy and Finance for an opinion on draft amendments (hereinafter the ‘draft amendments’) to Article 20 (hereinafter the ‘original provision’) of Law No 3867 of 2010 on private insurance supervision, the establishment of a private life insurance guarantee fund, credit rating agencies and other provisions falling within the competence of the Ministry of Finance (hereinafter the ‘draft amendments’). The ECB’s competence to deliver an opinion is based on Articles 127(4) and 282(5) of the Treaty on the Functioning of the European Union and Article 2(1), third indent, of Council Decision 98/415 , as the draft amendments relate to (1) the Bank of Greece and (2) the European System of Central Banks’ task to contribute to the smooth conduct of policies by the competent authorities relating to the stability of the financial system pursuant to Article 127(5) of the Treaty. In accordance with Article 17.5, first sentence, of the Rules of Procedure of the European Central Bank, the Governing Council has adopted this opinion.

1. Purpose of the draft amendments

1.1 The draft amendments restate and amend the original provision, which sets out the institutional framework, mandate, composition and powers of the Systemic Stability Council (hereinafter the ‘Council’). 1.2 According to the explanatory memorandum, the draft amendments have been proposed with a view to (1) ensuring the proper functioning of the Council and compliance with the principles of sound administration and effectiveness, and (2) strengthening the institutional framework for supervision and the management of systemic risks in the financial sector by facilitating faster and more informed assessments of information, continuous monitoring of market developments and the prompt submission of recommendations to the Council by two new subcommittees. 1.3 The draft amendments restate that the Council is established within the Ministry of National Economy and Finance and that its mandate comprises the responsibility to analyse the interaction and dynamics among the various systems of the financial sector and to continuously explore precautionary measures for addressing emergency or extreme situations and crises. In particular,

the Council: (1) monitors the relationship and dynamics among the systems of the economy, with particular emphasis on capital markets, the banking and insurance systems, liquidity, public debt and government guarantees, as well as on precautionary actions against extreme situations, instability and crises; (2) monitors the financial policy of the Ministry of National Economy and Finance and the needs related to financial stability, submits relevant recommendations, and examines issues arising within the framework of the functioning of the European supervisory institutions; and (3) monitors and ensures the exchange of information between the Ministry of National Economy and Finance and the national independent supervisory authorities of the financial sector, in order to coordinate the financial policy of the Ministry of National Economy and Finance. 1.4 The draft amendments also restate the composition of the Council, which consists of the following eight members: (1) the Minister for National Economy and Finance, (2) the Deputy Minister for National Economy and Finance or, where no Deputy Minister has been appointed, the Undersecretary of State for Fiscal Policy, (3) the Secretary-General for the Financial Sector and Private Debt of the Ministry of National Economy and Finance, (4) the Secretary-General for Economic Policy and Strategy of the Ministry of National Economy and Finance, (5) the Governor of the Bank of Greece, (6) the Deputy Governor of the Bank of Greece responsible for the relevant subject matter, (7) the Chair of the Hellenic Capital Market Commission, and (8) the Chair of the Public Debt Management Agency. The Chair of the Council is the Minister for National Economy and Finance, and is replaced by the Deputy Minister for National Economy and Finance, or, if no Deputy Minister has been appointed, by the Secretary-General for the Financial Sector and Private Debt of the Ministry of National Economy and Finance. In the event of a tie, the Chair is to have the casting vote. 1.5 The draft amendments require the Council to be convened at least once per year. 1.6 The draft amendments establish two subcommittees within the Council, namely a Crisis Management Committee and a Systemic Stability Committee, whose members each consist of the Director of the Financial Policy Directorate of the General Secretariat for the Financial Sector and Private Debt of the Ministry of National Economy and Finance, as well as designated representatives of the Bank of Greece, the Hellenic Capital Market Commission and the Hellenic Deposit and Investment Guarantee Fund. The draft amendments provide that these subcommittees assume, on a proportional basis, the responsibilities of the Council and its monitoring tasks. They meet every six months and, following each meeting, submit an informational memorandum to the Chair of the Council. 1.7 The draft amendments give the right to the Chair of the Hellenic Deposit and Investment Guarantee Fund to attend, upon invitation of the Chair of the Council, and without voting rights, the Council’s meetings. This is in addition to the same possibility currently given by the original provision to other officials such as governors, chairs or chief executive officers of credit institutions, specialised experts, and any other third party whose opinion the Chair of the Council considers would assist the Council’s work. 1.8 The draft amendments restate that the Chair and the Chief Executive Officer of the Hellenic Corporation of Assets and Participations (HCAP) is to be mandatorily invited to meetings of the Council where the discussion concerns credit institutions’ share capital in which the HCAP holds a

participation. The resolution authority is to be mandatorily invited for matters relating to resolution and is to participate in meetings without voting rights, represented by a person other than those designated to represent the relevant supervisory authority. 1.9 The draft amendments also replace the wording of the title as well as that which relates to the capacity of certain members of the Council to reflect organisational and institutional updates that have occurred within the respective bodies to whom these members belong.

2. General observations

2.1 The ECB was consulted and adopted an opinion on a draft version of the original provision establishing the Council in 2010 . The ECB understands that the Council has largely been inactive since its establishment, and that the draft amendments are essentially intended to operationalise the Council. 2.2 The ECB notes that, since 2014, the Bank of Greece is the macroprudential authority responsible in Greece for the adoption of the combined buffer requirement, the adoption of borrower-based measures and other macroprudential instruments . 2.3 The ECB in principle welcomes that all the relevant authorities and institutions involved in matters related to financial stability in Greece are represented in the Council , to the extent that this increases effective policy coordination. 2.4 As pointed out in previous opinions, the establishment of national financial stability committees may enhance the ability of national central banks (NCBs) and supervisory authorities to provide analytical support to the European Systemic Risk Board (ESRB) . However, it is necessary to avoid such national committees being entrusted with tasks and powers that potentially conflict with those of the ESRB and which may undermine its effectiveness. Moreover, the legal frameworks of these committees should appropriately reflect the NCBs’ roles, should not constrain the independence of their governors or unduly affect the quality and impartiality of their contributions as members of the ESRB, and should take account of the ECB’s macroprudential supervisory powers in the context of the Single Supervisory Mechanism. Lastly, in view of the importance of ensuring the effectiveness of macroprudential supervisory arrangements at Union level, it is essential to safeguard the ESRB’s ability to perform its tasks independently and to guarantee an authoritative and effective channel for transmitting its warnings and recommendations. Against this background, it is important that the draft

amendments ensure that the Council will function in a way that is fully consistent with the abovementioned principles. 2.5 In line with previous opinions , it is equally important that the tasks attributed to the Council do not undermine (1) the Bank of Greece’s institutional independence, or (2) the performance by the Bank of Greece of its ESCB-related tasks under the Treaty and the Statute of the European System of Central Banks and of the European Central Bank. The draft amendments should ensure that these aspects are clearly dealt with. 2.6 In that context, the draft amendments should also clearly set out that the Council’s recommendations for issues related to financial stability are only to be made to the Ministry of National Economy and Finance, so that the Bank of Greece’s independence as macroprudential authority is ensured. 2.7 Moreover, the draft amendments should ensure that the exercise by the Council of its task of monitoring and ensuring the exchange of information between the Ministry of National Economy and Finance and the national independent supervisory authorities of the financial sector is without prejudice to professional secrecy requirements and provisions ensuring the confidentiality of information received by the Bank of Greece in the course of its duties, which the Bank of Greece must adhere to itself .

This opinion will be published on EUR-Lex.

Done at Frankfurt am Main, 17 June 2026.

[signed]

The President of the ECB

Christine LAGARDE