EN ECB-PUBLIC 
 
 
OPINION OF THE EUROPEAN CENTRAL BANK 
of 27 March 2014 
on the measurement of credit and country risk of bank groups 
(CON/2014/23) 
 Introduction and legal basis 
On 25 February 2014, the European Central Bank (ECB) received a request from the Oesterreichische 
Nationalbank (OeNB) for an opinion on a draft regula tion on the detection of credit and country risk of 
groups of credit institutions and their foreign subs idiaries (hereinafter th e ‘draft regulation’). 
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 the third, f ourth and sixth indents of Article 2(1) of Council 
Decision 98/415/EC1, as the draft regulation relates to the OeNB , the collection of financial statistics and 
contains rules applicable to banks which materially  influence the stability of financial institutions and 
markets. In accordance with the firs t 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 regulation 1.1 The purpose of the draft regulation is to detect cr edit and country risk of Austrian groups of credit 
institutions and their foreign subsidiary banks. It  applies to superordinate credit institutions of 
Austrian groups of credit institutions within the meaning of Article 30(5)  of the Law on banking. 
Such superordinate credit institutions will be requi red to submit reports on credit and country risk 
to the OeNB on a quarterly basis. Reports are to be submitted in accordance with the four annexes 
to the draft regulation: (1) consolidated risk stat ement on credit risk (Annex A1), (2) risk statement 
on the credit risk for foreign subsidiary banks (A nnex A2), (3) consolidat ed risk statement on 
country risk (Annex B1) and (4) risk statement on the country risk of foreign subsidiary banks 
(Annex B2). The draft regulation will enter into fo rce on 1 July 2014 and will apply, for the first 
time, to reports on 30 September 2014. 
1.2 Article 44b(1) of the Law on Oesterreichische Na tionalbank (hereinafter the ‘Law on the OeNB’) 
requires the OeNB to monitor, in the public inte rest, all matters that may have an impact on 
safeguarding financial stability in Austria. In general, and based on a current reporting regulation of 
the Austrian Financial Market Authority (FMA) on assets, profits and risks of credit institutions, 
the FMA makes available the data necessary for th e OeNB to fulfil this task. The FMA regulation 
                                                            
1  Council Decision 98/415/EC of 29 June 1998 on the consulta tion of the European Central Bank by national authorities 
regarding draft legislative provisions (OJ L 189, 3.7.1998, p. 42). 
ECB-PUBLIC  
2 currently provides for the reports required under th e draft regulation. Following implementation of 
the CRD IV package2 and the reporting implementing technical standards of the European Banking 
Authority, with effect from the third quarter of  2014, the FMA will no longer collect data on credit 
and country risk of groups of credit institutions. However, the OeNB needs this data in order to 
continue to carry out its tasks in connection with the maintenance of financial stability. 
Accordingly, the OeNB envisages issuing the draft regulation on the basis of Article 44b(2) of the Law on the OeNB in order to collect information on credit and country risk of groups of credit 
institutions and their foreign subsidiary banks. 
 2. General observations  
The ECB understands that the draft regulation implem ents statistical data collection powers at the 
disposal of the OeNB under the Law on the OeNB, to  be applied in an area which is not presently 
harmonised through a Union legal act in the field of statistics. In this context, the ECB points to its 
Decision ECB/2014/6
3, establishing measures aimed at gradua l development of the ECB statistical 
framework in relation to the credit exposures of cr edit institutions, or other loan-providing financial 
institutions, vis-à-vis borrowers. Such prospective st atistical framework will ser ve the purpose of, inter 
alia, supporting the activities of the European System of Central Bank in the area of financial stability. 
The ECB invites the Austrian authorities to monitor the development of this ECB statistical framework, 
which framework may interact with the objectives of the draft regulation.  
 This opinion will be published on the ECB’s website.   Done at Frankfurt am Main, 27 March 2014. 
 
[signed] 
 
The President of the ECB 
Mario DRAGHI 
                                                            
2  Regulation (EU) No 575/2013 of the European Parliament and of the Council of 26 June 2013 on prudential requirements 
for credit institutions and investment firms and amending Re gulation (EU) No 648/2012 (OJ L 176, 27.6.2013, p. 1) and 
Directive 2013/36/EU of the European Parliament and of th e Council of 26 June 2013 on access to the activity of credit 
institutions and the prudential supervision of credit instit utions and investment firms, amending Directive 2002/87/EC 
and repealing Directives 2006/48/EC and 2006/49/EC (OJ L 176, 27.6.2013, p. 338). 
3  Decision ECB/2014/6 of 24 February 2014 on the organisation of preparatory meas ures for the collection of granular 
credit data by the European System of Central Banks, available at the E CB website (www.ecb.europa.eu); not yet 
published in the Official Journal.