EN 
 
 
OPINION OF THE EUROPEAN CENTRAL BANK 
of 2 August 2010 
on the minimum reserves framework 
(CON/2010/60) 
 
Introduction and legal basis  
On 23 July 2010 the European Central Bank (ECB) received a request from Eesti Pank for an opinion on 
the draft Governor decrees amending the procedure for calculating and complying with the reserve requirement and on the complementary report on the re serve requirement calculation (hereinafter 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/EC of 29 June 1998 on 
the consultation of the European Central Bank by  national authorities regarding draft legislative 
provisions
1, as the draft decrees relates 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.
  Purpose of the draft decrees 
The purpose of the draft decrees is to smooth the transition from the minimum reserve framework in 
Estonia to the Eurosystem minimum reserve system in  relation to the introduction of the euro in Estonia 
on 1 January 20112. First, the draft decrees provide for a gradual decrease in the minimum reserve 
requirement at 11% on 1 Septembe r 2010 and 7% on 1 November 2010. Second, reporting on the reserve 
requirement calculation is extended to meet the reporting requirements based on the Eurosystem 
minimum reserve framework. 
 2. General observations 2.1  The ECB has addressed Estonia’s minimum reserve system on two occasions
3. In both cases, it 
noted that differences between the Estonian and the Eurosystem’s minimum reserve systems would 
                                                 
1  OJ L 189, 3.7.1998, p. 42.  
2  As decided at a meeting of the Economic and Financial Affairs Council on 13 July 2010.  
3  See Opinions CON/2006/3 and CON/2006/59. All ECB opinions are published on the ECB’s website at 
www.ecb.europa.eu. 
2 need to be eliminated on adoption of the euro. Memb er States that have not adopted the euro retain 
their powers in the field of monetary policy, for wh ich they remain responsible. At the same time, it 
is beneficial for them to achieve consistenc y with the Eurosystem operational framework for 
monetary policy in due time so that credit institutions in those Member States can become 
acquainted with the requirements that will apply to th em when the euro is in troduced: in the current 
context the single reserve ratio of 2%.  
2.2 Estonia will be subject from 1 January 2 011 to the following minimum reserves framework: 
1) Article 19 of the Statute of the European System of Central Banks and of the European Central Bank; 2) Council Regulation (EC) No 2531/98 of  23 November 1998 concerning the application of 
minimum reserves by the European Central Bank
4; 3) Regulation ECB/2003/9; and 4) in relation to 
the definition and calculation of the reserve b ase, Regulation ECB/2008/32 of 19 December 2008 
concerning the balance sheet of the moneta ry financial institutions sector (recast)5. Article 11 and 
Annex III to Regulation ECB/2008/32 require the use of the statistical information by credit 
institutions reported under this Regulation for the purpose of mini mum reserves. Special rules set 
out in this Regulation prevail over Regulation ECB/2003/9 and concern small credit institutions, 
group reporting and reserve requirements in the case of mergers. 
2.3 The aim of the transitional regime foreseen by th e draft decrees is to contribute to the efficient 
functioning of the financial markets and a smooth adjustment of liquidity management. In this 
respect, it is helpful to ensure an adequate noti ce period before the application of the measures to 
allow credit institutions to adjust to the changes introduced by the dr aft decrees. It must also be 
stressed that these transitional measures will only apply until 31 December 2010 following which 
Estonia will adopt the euro. In this regard, it is note d that in the interests of legal clarity, the draft 
decrees should specify their expiry dates.  
2.4 It is also noted that the Decree on the complementary report could be clearer in setting 
requirements only for transitional reporting. It should also avoid any risk of confusion that could arise from Article 3 which concerns the minimum reserve ratio based on Regulation ECB/2003/9 of 
12 September 2003 on the application of minimum reserves
6. The current wording of this Article 
may be read as implying that the Eurosystem mini mum reserve ratio applies on entry into force of 
these draft decrees. 
 
                                                 
4  OJ L 318, 27.11.1998, p. 1.  
5  OJ L 15, 20.1.2009, p. 14. 
6  OJ L 250, 2.10.2003, p. 10.  
3 This opinion will be published on the ECB’s website. 
  Done at Frankfurt am Main, 2 August 2010. 
 
[signed] 
 
The President of the ECB 
Jean-Claude TRICHET