Opinion of the European Central Bank of 8 November 2023 on the minimum reserve requirements of the Magyar Nemzeti Bank (CON/2023/36)
Date: 2023-11-08
Institutions: European Central Bank
Subjects: legal basis

EN 

ECB-PUBLIC 

OPINION OF THE EUROPEAN CENTRAL BANK 

of 8 November 2023  

on the minimum reserve requirements of the Magyar Nemzeti Bank 

(CON/2023/36) 

Introduction and legal basis 

On 29 September 2023 the European Central Bank (ECB) received a request from the Magyar Nemzeti 

Bank (MNB) for an opinion on a draft MNB decree amending the MNB Decree on the calculation, method 

of allocation and placement of minimum reserves (hereinafter the ‘draft decree on required reserves’) and 

on a draft decree on the required reserve ratio (hereinafter the ‘draft decree on the required reserve ratio’) 

(hereinafter referred to collectively as 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 of a Member State that has not adopted the euro. 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 purpose of the draft decrees 

1.1  The draft decrees aim, from 1 January 2024, to introduce a new method of calculating the MNB’s 

reserve requirements based on the monthly average of bank balance sheet data and to remove the 

option to choose among different required reserve ratios. 

1.2  Currently, required reserves are calculated using the credit institution balance sheet date fixed as of 

31  March  2023  on  a  spot  basis  and  without  recourse  to  averaging 2.  The  ECB  adopted  Opinion 

CON/2023/163  in  relation  to  this  calculation  method.  According  to  the  explanatory  memorandum 

accompanying the draft decrees, this provisional solution will come to an end as both the MNB and 

credit  institutions  will  have  implemented  the  technical  developments  necessary  for  the  planned 

introduction of a permanent monthly averaging calculation method. 

1.3  The MNB first enabled credit institutions to choose from different reserve ratios in 2010 4, in relation 

to which the ECB adopted Opinion CON/2010/68. In 2022 the MNB reintroduced the option to choose 

among  reserve  ratios  for  certain  liabilities 5,  in  relation  to  which  the  ECB  adopted  Opinion 

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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). 
Article  3(3)  of  10/2005.  (VI.  11.)  MNB  rendelet  a  kötelező  jegybanki  tartalék  kiszámításáról,  illetve  képzésének  és 
elhelyezésének módjáról, published in Magyar Közlöny 2005/78. 
All ECB opinions are available on EUR-Lex. 
13/2010. (IX. 6.) MNB rendelet a kötelező tartalékráta mértékéről, published in Magyar Közlöny 2010/141. 

35/2022. (IX. 15.) MNB rendelet a kötelező tartalékráta mértékéről, published in Magyar Közlöny 2022/150. 

 
 
 
 
 
ECB-PUBLIC 

CON/2022/33. Under those provisions, a reserve ratio of 0 % applied to: (1) deposits and loans taken, 

the maturity of which at the time of appearing in the accounting records of the credit institution subject 

to  reserve  requirements  exceeds  two  years;  (2)  debt  securities,  provided  that  the  maturity  of  the 

securities at the time of the issuance exceeds two years; and (3) repos. Additionally, a reserve ratio 

of 5 %, 6 %, 7 %, 8 %, 9 % or 10 % applied to all other liabilities included in a credit institution’s reserve 

base, depending on the declaration of the credit institution subject to reserve requirements. Under 

the current MNB decree on the required reserve ratio6, the reserve ratio of 0 % is retained for the 

liabilities listed above, while the reserve ratio for all other liabilities included in a credit institution’s 

reserve  base  is  10 %,  11 %,  12 %,  13 %,  14 %  or  15 %,  depending  on  the  declaration  of  credit 

institutions subject to reserve requirements. The draft decree on the required reserve ratio would 

remove the option to choose among different required reserve ratios and introduce a uniform 10 % 

reserve ratio for those liabilities, while retaining the 0 % reserve ratio for liabilities for which the same 

ratio currently applies. 

2. 

General observations 

2.1  As previously noted by the ECB 7, Member States whose currency is not the euro retain their powers 

in the field of monetary policy according to national law8. On the introduction of the euro, Hungary’s 

monetary policy would be the single monetary policy for the euro and would need at that time to be 

consistent  with  the  Eurosystem’s  operational  framework.  Credit  institutions  should  therefore  be 

familiar with the requirements that will apply to them once the single monetary policy is implemented 

in Hungary. 

2.2  The  ECB  notes  that  the  draft  decree  on  the  required  reserve  ratio  removes  the  option  to  choose 

among  different  reserve  ratios,  thus  setting  out  reserve  ratio  requirements  more  in  line  with  the 

minimum  reserve  requirements  established  by  the  ECB9,  which  also  do  not  include  the  option  to 

choose among different reserve ratios. 

2.3 

In the euro area, minimum reserves are held and calculated on the basis of the sum of certain eligible 

liabilities10. In particular, credit institutions are required to calculate these liabilities with respect to a 

particular maintenance period on the basis of the data relating to the month two months prior to the 

month within which the maintenance period starts 11, in relation to which a maintenance period begins 

on  the  settlement  day  of  the  main  refinancing  operation  following  the  meeting  of  the  Governing 

Council at which the  assessment of the  monetary policy stance is pre-scheduled 12. In order for a 

credit institution to comply with the reserve requirements, the average end-of-day balance on one or 

more  of  its  reserve  accounts  over  the  maintenance  period  must  be  equal  to  or  must  exceed  the 

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6/2023. (III. 8.) MNB rendelet a kötelező tartalékráta mértékéről, published in Magyar Közlöny 2023/34. 
See, for example, paragraph 2.2 of Opinion CON/2023/16, paragraph 2 of Opinion CON/2023/6 and paragraph 2.6 of 
Opinion CON/2022/38. 
Article 282(4) of the Treaty on the Functioning of the European Union and Article 42.2 of the Statute of the European 
System of Central Banks and of the European Central Bank. 
See Article 6(1) 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). 
See Articles 3, 5 and 6 of Regulation (EU) 2021/378 (ECB/2021/1).  
Article 5(5) of Regulation (EU) 2021/378 (ECB/2021/1). 

Article 8(1) of Regulation (EU) 2021/378 (ECB/2021/1). 

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amount  calculated  for  that  period13.  The  ECB  notes  that  the  draft  decree  on  required  reserves 

introduces  a  monthly  averaging  calculation  method  for  the  required  reserves,  thereby  ending  the 

provisional solution described in paragraph 1.2 above. 

ECB-PUBLIC 

This opinion will be published on EUR-Lex. 

Done at Frankfurt am Main, 8 November 2023. 

[signed] 

The President of the ECB 

Christine LAGARDE 

13  

Article 3(1), point (a), in conjunction with Article 6 of Regulation (EU) 2021/378 (ECB/2021/1). Under Article 2, point 
(11), of Regulation (EU) 2021/378 (ECB/2021/1), ‘end-of-day balance’ means the reserve holdings at the time when 
the  finalisation  of  payment  activities  has  taken  place  and  entries  relating  to  access  to  the  standing  facilities  of  the 
Eurosystem have been made. 

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