Opinion of the European Central Bank of 9 December 2015 on consumer credit (CON/2015/54)
Date: 2015-12-09
Institutions: European Central Bank
Subjects: Czechia, central bank, consumer credit, credit institution, financial supervision, national law

EN 

ECB-PUBLIC 

OPINION OF THE EUROPEAN CENTRAL BANK 

of 9 December 2015  

on consumer credit 

(CON/2015/54) 

Introduction and legal basis 

On 6 October 2015 the European Central Bank (ECB) received a request from the Minister of Finance of 

the Czech Republic for an opinion on a draft law on consumer credit (hereinafter the ‘draft law’). 

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 indent of Article 2(1) of Council Decision 98/415/EC1, as 

the draft law relates to a national central bank. 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 law 

1.1  The purpose of the draft law is to transpose into Czech law Directive 2014/17/EU of the European 
Parliament and of the Council2 and parts of Directive 2008/48/EC of the European Parliament and 
of  the  Council3,  whilst  also  building  on  certain  relevant  EU  provisions  in  Commission  Delegated 
Regulation  (EU)  No  1125/2014 4.  The  draft  law  also  seeks  to  regulate  the  activities  of  authorised 

providers and intermediaries of consumer credit, including their activities abroad, and the rights and 

obligations of parties in the provision and intermediation of consumer credit.  

1.2  The principal provisions of the draft law:  

(1)  

set out which types of authorised entity may provide and intermediate consumer credits 5 as 

part of its business activity in the Czech Republic, subject to the provisions of the draft law, 
with  such  entities  including  also  non-banks6  (hereinafter  ‘consumer  credit  providers  and 

1  

2  

3  

4  

5  
6  

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). 
Directive  2014/17/EU  of  the  European  Parliament  and  the  Council  of  4  February  2014  on  credit  agreements  for 
consumers  relating  to  residential  immovable  property  and  amending  Directives  2008/48/EC  and  2013/36/EU  and 
Regulation (EU) No 1093/2010 (OJ L 60, 28.2.2014, p. 34). 
Directive  2008/48/EC  of  the  European  Parliament  and  the  Council  of  23  April  2008  on  credit  agreements  for 
consumers  and  repealing  Council  Directive  87/102/EEC  (OJ  L  133,  22.5.2008,  p.  66).  The  draft  law  will  overhaul 
Law 145/2010 Coll. on consumer credit, which implements Directive 2008/48/EC, 

Commission Delegated Regulation (EU) No 1125/2014 of 19 September 2014 supplementing Directive 2014/17/EU 
of  the  European  Parliament  and  of  the  Council  with  regard  to  regulatory  technical  standards  on  the  minimum 
monetary  amount  of  the  professional  indemnity  insurance  or  comparable  guarantee  to  be  held  by  credit 
intermediaries (OJ L 305, 24.10.2014, p. 1). 

As defined in Article 2 and subject to the exemptions set out in Article 4 of the draft law.  
See  Article  7  of  the  draft  law.  The  addition  of  non-banks  to  the  list  of  entities  which  may  be  authorised  b  ČNB  to 
provide  or  intermediate  consumer  credit  will  require  a  small  amendment  to  the  Act  on  Česká  národní  banka  No. 
6/1993 Coll., as amended. 

 
 
 
 
                                                 
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intermediaries’),  and  the  activities  that  come  under  the  provision  and  intermediation  of 
consumer credit7;  

(2)   place  consumer  credit  providers  and  intermediaries  under  the  oversight  and  supervision  of 

Česká národní banka (‘ČNB’) 8; and  

(3)   overhaul  the  current  legal  framework  regulating  such  entities  and  the  provision  of  such 

services  and  ČNB’s  supervisory  and  regulatory  powers  with  respect  to  such  entities, 

including the conditions for their authorisation, the maintenance by ČNB of a public register 

of such entities, and ČNB’s power to charge fees for their authorisation and for renewals of 
authorisation, so as to finance ČNB’s costs related to their supervision 9.  

1.3   The  ECB  understands  that  to  date  non-banking  credit  providers  and  intermediaries  have  been 

licensed by trade offices (“živnostenský úřad”), that they have been only lightly regulated and that 

they  have  been  supervised  by  the  Czech  Trade  Inspection  Authority,  which  falls  under  the 
jurisdiction of the Ministry of Industry and Trade10. 

1.4  The  ECB  understands  that  there  is  a  disagreement  between  the  Ministry  of  Finance  and  ČNB 

insofar  as  ČNB  is  not  willing  to  assume  this  new  supervisory  task.  The  ECB  trusts  that  this 

disagreement  will  be  resolved  at  national  level  with  due  regard  to  the  principle  of  central  bank 

independence.  

2. 

General observations  

2.1  The  ECB  understands  that  the  draft  law  will  bring  consumer  credit  providers  and  intermediaries 

under  the  supervision  of  ČNB.  The  ECB  takes  note  of  the  intention  of  the  legislator  to  achieve  a 

consistently  high  level  of  supervision  also  for  non-bank  consumer  credit  providers.  However,  the 

ECB also notes that to date non-banking consumer credits have had negative social impacts in the 

Czech Republic.  

2.2  The  draft  law  expands  ČNB’s  powers  to  supervise  also  non-bank  consumer  credit  providers  and 

intermediaries, thus broadening and extending ČNB’s current responsibilities for the supervision of 

the same activities when undertaken by licensed credit institutions. The ECB underlines that, in the 

context of a proposed conferral of new tasks on an ESCB member, it is necessary to assess such 

conferral  against  the  prohibition  of  monetary  financing  under  Article  123  of  the  Treaty.  The  ECB 

has  developed  the  guidance  set  out  in  paragraphs  2.2.1  to  2.2.3  of  this  opinion,  in  the  form  of 

7  
8   

9  

10  

See Article 3(1)(a) and (b) of the draft law. 

See Part X (Oversight) of the draft law. Currently ČNB supervises consumer credit only if provided or intermediated 
by  entities which it supervises (i.e. credit institutions, foreign bank branches, electronic money institutions, savings 
banks and credit cooperatives). 
See  amended  item  65,  point  9  of  Annex  II  to  the  accompanying  draft  law  amending  Law  No.634/2004  on 
administrative  fees.  As  regards  ČNB’s  statutory  power  to  set  administrative  fees  for  authorising  and  renewing  of 
authorisation of consumer credit providers and of intermediaries, see Article 12(2) and Articles 20 and 31 of the draft 
law respectively. 
Under the current Law 145/2010 Coll. on consumer credit, the Czech Trade Inspection Authority is responsible for 
supervising  the  provision  and  intermediation  of  consumer  credit  by  non-banks  (with  Trade  Licensing  Offices  being 
responsible for issuing trade licences to the entities concerned), unless, as part of these activities, the entities offer 
payment services, e.g. issue of credit cards, in which case they are licensed as payment institutions and supervised 
by ČNB. 

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general  and  specific  considerations,  on  the  basis  of  which  it  may  decide  whether  a  new  task 

conferred on an ESCB national central bank (NCB) is to be considered a central banking task or a 

government task for the purposes of assessing such conferral against the prohibition of monetary 
financing  under  Article 123  of  the  Treaty11.  The  concrete  assessment  of  whether  ČNB’s  task  of 

supervising  consumer  credit  providers  and  intermediaries  is  to  be  considered  a  central  banking 

task or a government task is then undertaken in paragraph 3.1 of this opinion. 

2.2.1  General considerations 

First,  the  systematic  categorisation  of  tasks  assigned  to  NCBs  as  central  banking  or  government 

tasks applies to genuinely new tasks that did not exist in the past or did not form an integral part of 

the  central  banking  tasks already  assigned  to  the  NCB  in  the  past.  In  recognition  of  the  different 

Member  States’  legal  frameworks,  central  banking  traditions  and  national  set-ups,  the  tasks 

currently discharged by an NCB as central banking tasks are not reviewed and re-categorised, but 

may be reassessed if their substance is amended. 

Second, it needs to be emphasised that when Member States decide to confer new tasks on their 

NCBs,  due  regard  must  be  given  to  the  role  of  the  NCB  as  part  of  the  ESCB  or  Eurosystem,  as 

applicable,  and  to  the  requirement  of  central  bank  independence.  The  principle  of  financial 

independence, which is a key aspect of the principle of central bank independence as laid down in 

Article  130  of  the  Treaty,  requires  that  the  Member  States  may  not  put  their  NCBs  in  a  position 

where  they  have  insufficient  financial  resources  to  carry  out  their  ESCB-  or  Eurosystem-related 

tasks, as applicable. Accordingly, an NCB must have sufficient financial means not only to perform 

its ESCB- or Eurosystem-related tasks but also its national tasks (e.g. financing its administration 
and own operations) 12. Where an NCB considers that the allocation of a new task would impinge 

on its financial independence, because it would not have sufficient means to focus primarily on its 

ESCB-  or  Eurosystem-related  tasks,  or  that  the  discharge  of  the  new  task  would  impose  a 

disproportionate burden on it, the NCB should be able to object to the new task being allocated to 

it.  

Third, central banking tasks comprise in particular those tasks that are related to the tasks listed in 

Article 127(2), (5) and (6) of the Treaty. 

Fourth,  new  tasks  conferred  on  an  NCB  which  are  atypical  of  NCBs’  tasks,  or  which  are  clearly 

discharged on behalf of and in the exclusive interest of the government or of other public entities, 

should be considered as government tasks. In that context, a distinction should be drawn between 

NCBs’  liquidity-  and  solvency-related  tasks.  While,  for  the  purposes  of  the  monetary  financing 

prohibition, solvency support is a government task, liquidity-related tasks, the ultimate objective of 

which are to finance the economy, are central banking tasks. 

11  
12  

See Opinion CON/2015/22. All ECB opinions are published on the ECB’s website at www.ecb.europa.eu. 
See the ECB’s 2014 Convergence Report, p. 25. 

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2.2.2  Specific considerations 

Banking supervision and macro-prudential tasks are central banking tasks when discharged by an 

NCB,  provided  they  do  not  undermine  its  independence  in  accordance  with  Article  130  of  the 

Treaty.  

An important criterion for qualifying a new task as a government task is the impact of the task on 

the institutional, financial and personal independence of the NCB. In particular, the following should 

be taken into account. 

First,  it  should  be  assessed  whether  the  performance  of  the  new  task  creates  inadequately 

addressed  conflicts  of 

interests  with  existing  central  banking 

tasks,  without  necessarily 

complementing  the  existing  central  banking  tasks.  If  a  conflict  of  interest  arises  between  existing 

and new tasks, there should be sufficient mitigation measures in place to adequately address that 

conflict.  Complementarity  between  the  new  task  and  existing  central  banking  tasks  should  not, 

however, be interpreted broadly, as this could lead to the creation of an indefinite chain of ancillary 

tasks. The assessment of the complementarity of the new task should also take into account the 

financing  of  that  task.  In  the  event  of  a  conflict  of  interest  between  prudential  supervision  and 
consumer protection prudential supervisory considerations must prevail 13. 

Second,  it  should  be  assessed  whether  without  new  financial  resources  the  performance  of  the 

new task places a disproportionate burden  on the financial or  organisational capacity of the NCB 

and may negatively impact on its capacity to properly perform existing central banking tasks. 

Third,  it  should  be  assessed  whether  the  performance  of  the  new  task  is  aligned  with  the 

institutional  set-up  of  the  NCB,  in  particular  as  regards  central  bank  independence  and 

accountability considerations. 

Fourth, it should be assessed whether the performance of the new task entails substantial financial 

risks. 

Fifth, it should be assessed whether the performance of the new task exposes the members of the 

NCB’s decision-making bodies to political risks that are disproportionate and could also impact on 

their personal independence and, in particular, the guarantee of the Governor’s term of office under 

Article 14.2 of the Statute of the European System of Central Banks and of the European Central 

Bank. 

2.2.3  Any  final  assessment  on  the  qualification  of  a  task  given  to  an  NCB  as  either  falling  within  the 

scope of a central banking task or a government task will be guided by the objective of ensuring the 

consistent  application  of  the  prohibition  of  monetary  financing  within  the  Eurosystem  and  the 

ESCB. 

13  

See paragraph 3.1 of CON/2015/21. 

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3. 

Specific observations 

3.1  Conferral on ČNB of the task of supervising consumer credit providers and intermediaries 

The draft law designates ČNB as the supervisory authority for non-bank consumer credit providers 

and intermediaries, thus broadening its current functions and activities. The ECB understands that 

up to now this segment of the financial market has been regulated in an unsatisfactory manner. In 

the light of the guidance set out in paragraphs 2.2.1 to 2.2.3, it must be assessed whether ČNB’s 

new tasks could constitute a breach of the monetary financing prohibition. 

3.2  Principle of financial independence  

The  principle  of  financial  independence  requires  NCBs  to  have  sufficient  means  to  carry  out  not 

only their ESCB-related tasks but also their national tasks, both from an operational and financial 
perspective14. In this regard the ECB notes that the draft law provides that ČNB has the power to 

require  that  consumer  credit  providers  and  intermediaries  pay  ČNB  fees  for  authorisations  and 
renewals of authorisations 15. The staff of such entities will need to acquire the relevant professional 

qualifications in order to be able to perform these activities. However, this  will be achieved under 

the responsibility and at the cost of the supervised entity, with ČNB acting only as the accrediting 

body for such qualifications. This should ensure that the cost of authorising market participants for 

such activities is met by the industry. However, the costs of carrying out supervision by ČNB might 

not be fully covered by the fees collected. The new task is expected to lead to increased staffing 
and operational costs for ČNB16.  

3.3 

Links to tasks listed in Article 127(5) of the Treaty  

The supervision of consumer credit providers and intermediaries can be considered a task related 

to  those  referred  to  in  Article  127(5)  of  the  Treaty,  based  on  the  understanding  that  it  is 

complementary to the supervisory tasks exercised by the NCB, particularly where, as in this case, 

ČNB  already  supervises  credit  institutions,  including  their  consumer  credit  activities,  and  has  the 

task of ensuring the stability of the financial system. 

Moreover,  point  2  of  Annex  1  to  Directive 2013/36/EU  of  the  European  Parliament  and  of  the 
Council17 lists the provision and intermediation of consumer credit as activities that are subject to 

mutual recognition. Such activities may thus be carried out across borders by credit institutions and 

non-banks  authorised  and  supervised  by  the  competent  authorities  of  another  Member  State, 
provided  that  such  activities  are  covered  by  the  relevant  authorisation  of  the  entity  concerned 18. 

From  this  perspective,  it  makes  sense  to  designate  ČNB  as  the  only  competent  authority  in  this 

area in the Czech Republic. 

14  
15  

16  

17  

18  

See ECB 2014 Convergence Report, p. 25. 
See  footnote  9  for  provisions  on  the  administrative  fees  that  ČNB  will  charge  for  providers’  and  intermediaries’ 
authorisations and renewals of authorisations.  

For  example,  ČNB’s  branch  network  may  face  an  increased  work  load  as  a  result  of  having  to  deal  with  public 
complaints about local non-bank consumer credit providers. 

See Annex 1 to Directive 2013/36/EU of the European Parliament and of the Council of 26 June 2013 on access to 
the activity of credit institutions and the prudential supervision of credit institutions 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). 

See also Opinion CON/2015/37. 

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3.4  Atypical tasks 

A  number  of  Member  States  have  conferred  on  their  NCBs  supervisory  tasks  related  to  the 
provision  of  consumer  credit19.  The  ECB  has  generally  accepted  the  allocation  of  such  tasks  to 
NCBs provided they do not interfere with the performance of the NCB’s ESCB-related tasks20. The 

tasks of an NCB with regard to the supervision of consumer credit providers and intermediaries can 

therefore, if this condition is met, be regarded as tasks not atypical of a central bank, particularly if, 

as  in  the  case  of  ČNB,  it  has  a  statutory  responsibility  for  banking  supervision  and  financial 
stability21. It is important however that appropriate resources are available to ensure that ČNB can 
properly perform these functions 22. 

3.5   Discharge of tasks on behalf of and in the exclusive interest of the Government or of other public 

entities 

ČNB  is  designated  as  the  sole  supervisory  authority  for  consumer  credit  providers  and 

intermediaries  in  its  own  name.  However,  background  documentation  regarding  the  draft  law 

indicates  that  this  designation  is  proposed  by  the  Ministry  of  Finance  as  a  reaction  to  a  social-

economic problem associated with the indebtedness of some parts of the population in the Czech 
Republic 23.  

3.6  Extent to which conflicts of interests with existing ČNB tasks are addressed and the performance of 

tasks is aligned with ČNB’s institutional set-up, in particular as regards central bank independence 

and accountability considerations 

As  the  supervisor  of  consumer  credit  providers  and  intermediaries,  ČNB  will  also  be  responsible 

under  the  draft  law  for  applying  consumer  protection  rules  to  such  entities.  As  the  authority 

responsible  for  supervising  the  financial  markets,  ČNB  will  be  required  to  mitigate  any  potential 

conflict of interests between its consumer protection tasks and its banking supervision and financial 

stability  mandates,  by  always  taking  the  latter  into  account  when  imposing  a  sanction  or 

enforcement  measure  in  relation  to  a  breach  of  an  obligation  in  the  field  of  financial  consumer 

protection.  Sufficient  mitigation  measures  must  be  put  in  place  to  ensure  that,  in  the  event  of  a 
conflict  of  interest,  prudential  supervisory  considerations  will  prevail24.  In  this  regard,  given  the 

complementarity of the new task of supervising consumer credit providers and intermediaries with 

ČNB’s existing supervisory tasks, the new task may be said to fit into ČNB’s institutional set-up. 

There  is  however  a  reputational  risk  that,  despite  the  proposed  more  stringent  regulation  and 

supervision  of  consumer  credit  providers  and  intermediaries,  ČNB  could  be  held  accountable  by 

the general public for problems related to the indebtedness of society and unlawful usury.  

19  

20  

21  
22  
23   

24  

According to the Ministry of Finance’s explanatory memorandum to the draft law, there are 7 NCBs which currently 
carry out such supervisory tasks in the European Union. 

See,  for  example,  paragraphs  2.1-2.3  of  Opinion  CON/2006/38,  paragraphs  2.1  and  2.2  of  Opinion  CON/2006/47, 
paragraphs 2.1-2.5 of Opinion CON/2007/29 and paragraph 2 of Opinion CON/2009/71. 

Articles 2 and 44 of the Act on the Czech National Bank No 6/1993 Coll., as amended. 
See further paragraph 3.7 below 

See    Parliamentary  Resolution  no.  367/2014  as  published  in  the  Parliamentary  Gazette,  Issue  no.  41  and  the 
Regulatory  impact  assessment  (RIA)  for  the  draft  law:  http://www.mfcr.cz/cs/soukromy-sektor/spotrebitelsky-
uver/distribuce-uveru-pro-spotrebitele/zahajeni-mezirezortniho-pripominkoveho-r-21716 

See paragraph 3.1 of CON/2015/21. 

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3.7  Extent  to  which  the  performance  of  tasks  is  proportionate  to  ČNB’s  financial  and  operational 

capacity and its ability to perform its ESCB-related tasks 

As  noted  above,  in  order  to  remain  financially  independent,  NCBs  must  have  sufficient  means  to 

carry out not only their ESCB-related tasks but also their national tasks, both from an operational 

and financial perspective. The ECB understands that the draft law’s regulatory impact assessment 

does  not  contain  a  precise  estimate  of  the  direct  costs  that  ČNB  is  likely  to  incur  by  also 
supervising non-bank consumer credit providers and intermediaries 25. In this regard, however, the 

ECB  welcomes  the  fact  that  the  draft  law  provides  that  consumer  credit  providers  and 

intermediaries  will  be  charged  administrative  fees  for  the  issuance  of  authorisations  to  carry  out 

such activities and for the renewal of such authorisations.  However, the ECB presumes that these 

fees would not cover all of ČNB’s costs related to this supervision. 

The  ECB  also  understands  that  this  new  task  will  lead  to  ČNB  having  to  address  more  punitive 

administrative  cases.  In  accordance  with  Czech  administrative  law,  the  ECB  understands  that 

these cases are heard by two instances. Although ČNB may recruit sufficient staff to deal with the 

cases at first instance, it is only ČNB’s seven-member Bank Board that may take a final decision at 

second instance. Therefore, from an operational perspective, the ECB is concerned as to whether 

ČNB’s  Bank  Board  will  have  sufficient  capacity  to  properly  handle  its  core  central  banking  and 

ESCB-related  tasks  together  with  these  new  consumer  protection  cases.  Furthermore,  the 

workload of ČNB’s Bank Board related to consumer cases might be disproportionate in comparison 

to its core central banking, ESCB-related, prudential supervisory and macro-prudential tasks. 

3.8  Extent to which the performance of tasks entails substantial financial risks  

As  in  the  case  of  other  State  authorities  performing  public  functions,  ČNB’s  potential  liability  for 

damages and/or costs arising from any  breaches  of law or improper administrative procedures in 

the supervision of such entities under the draft law, will be subject to the usual rules on liability for 
damage caused during the exercise of State Authority26.  

The  ECB  notes  that  the  explanatory  memorandum  to  the  draft  law  considers  that  taking  on  the 

supervisory responsibility for a sector, which has for many  years been only  lightly regulated, may 
entail - apart from the additional financial burden - reputational risks for ČNB27. The ECB also notes 

that the draft law includes powers to supervise such entities, so that if those powers are effectively 

used and enforced any reputational risks can be minimised. 

25  

26  

27  

See  the  Ministry  of  Finance  explanatory  memorandum  to  the  draft  law,  and  p.  65  of  the  Regulatory  impact 
assessment (RIA), which includes only a broad range of estimated annual costs as provided by ČNB:    
http://www.mfcr.cz/cs/soukromy-sektor/regulace/spotrebitelsky-uver/distribuce-uveru-pro-spotrebitele/zahajeni-
mezirezortniho-pripominkoveho-r-21716. 
Pursuant to the Act No. 82/1998 Coll. on State liability, as amended, the State is primarily liable for damage caused 
by an unlawful decision or improper administrative action by a legal entity or person in the course of exercising public 
authority on the State’s behalf. In this case that entity would be ČNB as the competent supervisory authority. Should 
the State be held liable for any breach of ČNB’s legal obligations, the State may request it to indemnify the State but 
only for damage caused by ČNB’s culpable conduct, such as negligence and wilful misconduct. 
See  the  Ministry  of  Finance’s  explanatory  memorandum  to  the  draft  law  as  referred  to  in  footnote  25,  where  the 
possible reputational risk for ČNB is acknowledged.  

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4.  

Conclusion 

The  ECB  considers  that  there  are  grounds  for  regarding  ČNB’s  new  task  of  supervising  non-bank 

consumer  credit  providers  and  intermediaries  as  a  central  banking  task  in  the  sense  that  it  can  be 

regarded as complementing CNB’s existing banking supervisory functions in the area of consumer credit, 

provided  it  does  not  undermine  ČNB’s  independence.  As  the  authority  responsible  for  supervising  the 

financial  markets,  ČNB  should  put  in  place  measures  to  mitigate  any  potential  conflict  of  interests 

between its consumer protection tasks in respect of such entities and its existing banking supervision and 

financial stability mandates, to ensure that in the event of a conflict, the latter mandates prevail. 

There are concerns that by proposing that ČNB perform the new task under the draft law the authorities 

are reacting to a social-economic problem connected to the indebtedness of some parts of the population 

in  the  Czech  Republic,  which  is  a  problem  not  purely  related  to  financial  supervision.  There  are  also 

concerns relating to the operational and reputational risks connected with vesting ČNB with supervisory 

tasks in the area of non-bank consumer credit. These aspects should be considered in more depth by the 

relevant Czech authorities before the draft law is adopted. 

As regards the principle of financial independence, the fact that the supervised entities will contribute to 

the cost of ČNB performing the new supervisory tasks, by paying authorisation fees, has a positive impact 

on ČNB’s financial capacity to assume these tasks. This notwithstanding, it should be ensured that ČNB 

has  sufficient  human  and  material  resources  to  carry  out  the  new  tasks  without  affecting  its  capacity  to 

carry  out  its  core  central  bank,  ESCB-related  and  prudential  supervisory  tasks.  Hence,  ČNB  should  be 

able  to  object  to  the  conferral  of  the  new  tasks  on  financial  independence  grounds,  for  example  if 

assuming the task would mean that either ČNB would not have sufficient means to focus primarily on its 

ESCB-related tasks or the discharge of the new tasks would impose a disproportionate burden on it.  

This opinion will be published on the ECB’s website.  

Done at Frankfurt am Main, 9 December 2015. 

[signed] 

The President of the ECB 

Mario DRAGHI 

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