EN ECB -PUBLIC  
 
OPINION OF THE EUROPEAN CENTRAL BANK  
of 12 September  2022  
on the reserve ratio  and minimum reserves  
(CON/20 22/33) 
 
 
Introduction and legal basis  
On 11 August 2022 t he European Central Bank (ECB) received a request from the Magyar Nemzeti Bank 
(MNB) for an opinion on the draft decree of the Governor of the Magyar Nemzeti Bank on the reserve ratio 
(hereinafter  the ‘draft decree on the reserve ratio’ ) and the draft decr ee on the calculation, the method of 
allocation and placement of minimum reserves (hereinafter the ‘draft decree on minimum reserves ’) 
(hereinafter, collectively the ‘draft decrees’) . 
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(2) of Council Decision 98/415/EC1, as the draft decrees 
relate to the instruments of monetary policy . In accordance with the first sentence of Article 17.5 of the 
Rules  of Procedure of the European Central Bank, the Governing Council has adopted this opinion.  
 
1. Background and p urpose of the draft D ecree s 
1.1 In 2016 the Governor of the MNB adopted Decree 45/20162 on the reserve ratio, in relation to which 
the ECB adopted Opinion CON/2016/563. Decree 45/2016 provided that a  reserve ratio of 0  % would 
apply to: (a) deposits and loans received with a remaining maturity of over two years at the time they 
are entered into the balance sheet of the credit institution; (b) debt securities issued with an agreed 
maturity over two years; and (c) repos . Further, a reserve ratio of 1% would apply to all other liabilities 
included in the reserve base of a credit institution subject to reserve requirements. The draft decree on the reserve ratio  proposes to increase the reserve ratio referred to above  from 1%  to 5 %, 6  %, 7 
%, 8 %, 9 % or 10 %, depending on the declaration of the credit institution that is subject to reser ve 
requirements. In the absence of a  declaration,  the reserve ratio will  be 5 %. The draft decree on the 
reserve ratio proposes to retain the 0% reserve ratio regarding the liability categories listed above 
under (a)-(c). 
 
 
1  Council Decision 98/415/EC of 29  June 1998 on the consultation of the European Central Bank by national authorities 
regarding draft legislative provisions ( OJ L 189, 3.7.1998, p. 42). 
2  MNB Decree 45/2016 (XI.23.) on the reserve ratio, published in Magyar Kö zlöny  2016/180.  
3 All ECB Op inions are available  on EUR -Lex. 
ECB -PUBLIC  
2 1.2 In 2005 the Governor of the MNB adopted Decree 10/20054 on the calculation, the method of 
allocation and placement of minimum reserves . That Decree was amended in 20185, in which 
connection the ECB  adopted Opinion CON/2018/48 on the proposed draft  amendments.  Decree 
10/2005 provided that the credit institutions subject to minimum reserve requirements must comply 
with the reserve requirement once a month, on the last calendar day of the maintenance period,  by 
applying the average calculation for the calendar day s of the maintenance period.  The draft decree 
on minimum reserves  proposes to amend the method of calculation by introducing a partial averaging 
mechanism according to which credit institutions must  hold the lowest level of minimum reserves  
applicable to that institution on each calendar day of the maintenance period . Credit institutions must 
also comply with the additional reserve requirements applicable to them depending on their 
declaration on a monthly basis, on the last calendar day of the maintenance period.  
1.3 The draft decree on minimum reserves proposes t he introduction of  a new kind of penalty  for case s 
of reserve deficiencies : the MNB may debit the forint settlement account of the credit institution with 
an amount proportional to the shortfall of the reserve holding amount, with an interest rate 
corresponding to twice the prevailing central bank policy rate effective on the day of the shortfall.  
 
2. Observations   
2.1 The ECB takes note of the draft decrees. As n oted in earlier opinions6, Member States whose 
currency is not the euro retain their powers in the field of monetary policy. Once the euro is 
introduced, Hungary’s monetary policy will be the single monetary policy and will need to be the 
consistent with the Eurosystem’s operational  framework7.  
2.2 The ECB supports  legal clarity8. In that regard, and to increase consistency with the Eurosystem’s 
operational framework9, the term ‘minimum reserves ’ should be used in both draft decrees10. 
 
This opinion will b e published on EUR -Lex.  
 
 
 
4  MNB Decree 10/2005.(VI.11.) on the calculation, method of allocation and placement of minimum reserves, published  
in Magyar Közlöny 78.  
5  MNB Decree 43/2018.  (XI.21.) on  the amendment of MNB Decree 10/2005. (VI.11.) on  the calculation, method of 
allocation and placement of minimum reserves, published in Magyar Közlöny 182. 
6  Opinion CON/2010/68, Opinion CON/2015/39, Opinion CON/2016/56 and Opinion CON/2018/48. 
7 Credit institutions should therefore be familiar with the requirements that will apply to them once the single monetary 
policy is implemented in Hungary.  
8   See recital 3 of Regulation (EU) 2021/378 of the European Central Bank of 22 January 2021 on the application of  
minimum reserve requirements (ECB/2021/1) (OJ l 73, 3.3.2021, p. 1) . 
9 See Article  2, points (1) and (9) , of Regulation (EU) 2021/378 (ECB/2021/1) . 
10 The term  ‘minimum central bank reserves ’ should be replaced with the term ‘minimum reserves’ . 
ECB -PUBLIC  
3 Done at Frankfurt am Main, 12 September  2022.  
 
[signed]  
 
The President of the ECB  
Christine  LAGARDE