European regulators have opened a consultation on updated rules for checking whether senior bank and investment firm leaders are suitable for their roles, with feedback invited until 25 May 2026.
The consultation covers revised joint guidelines on assessing the suitability of members of a firm’s management body — such as board members — and “key function holders”, which can include senior roles like heads of control functions and chief financial officers, according to a statement from the European Banking Authority (EBA) and the European Securities and Markets Authority (ESMA) issued on Wednesday.
The draft updates include new requirements for large institutions under the revised Capital Requirements Directive (CRD), including the use of “ex-ante” applications in cases where supervisors carry out “ex-post” assessments — meaning information may be submitted in advance even if the formal assessment happens after an appointment.
The guidelines also set out mandatory suitability assessments by competent authorities for certain key roles, and add further detail on requirements for branches of firms from outside the EU.
They also link suitability checks more closely with rules on anti-money laundering and countering the financing of terrorism, including guidance on identifying reasonable grounds to suspect money laundering or terrorist financing risks.
What large institutions would need to submit
Alongside the joint guidelines, the EBA is consulting on draft Regulatory Technical Standards (RTS) setting out the documentation and information that large institutions must submit to supervisors as part of suitability assessments.
The RTS would harmonise the minimum content of key documents such as suitability questionnaires and CVs, as well as firms’ internal suitability assessments, to make submissions “consistent, complete and comparable” across the EU, according to the EBA.
A public hearing on the guidelines is scheduled for 15 April 2026 from 14:00 to 15:30, followed by a hearing on the RTS from 15:30 to 16:30.
All contributions received will be published after the consultation ends unless respondents ask otherwise.
