Opinion of the European Central Bank of 6 february 2026 on the macroprudential role of Sveriges Riksbank and on certain macroprudential measures (CON/2026/5)
Date: 2026-02-06
Institutions: European Central Bank
Subjects: financial stability, legal basis

ECB-PUBLIC 

EN 

OPINION OF THE EUROPEAN CENTRAL BANK 

of 6 February 2026  

on the macroprudential role of Sveriges Riksbank and on certain macroprudential measures  

(CON/2026/5) 

Introduction and legal basis 

On 16 January 2026, the European Central Bank (ECB) received a request from the Swedish Ministry of 

Finance for an opinion on a referral to the Swedish Council on Legislation, dated 18 December 2025, on 

the development of the macroprudential area (hereinafter the ‘referral’), containing a draft law on restrictions 

on  mortgage  credits  (hereinafter  the  ‘draft  law’)  and  draft  amendments  to  the  Law  on  capital  buffers 1 

(hereinafter the ‘draft amendments’, together with the draft law, the ‘draft legislation’). 

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(1), third and sixth indents, of Council Decision 98/415/EC 2, 

as the draft legislation relates to Sveriges Riksbank and rules applicable to financial institutions insofar as 

they materially influence the stability of financial institutions and markets. In accordance with Article 17.5, 

first sentence, of the Rules of Procedure of the European Central Bank, the Governing Council has adopted 

this opinion. 

1. 

Purpose of the draft legislation 

1.1  The overall purpose of the draft law is to contribute to a sound amortisation culture in Sweden, lower 

the thresholds in the housing market and create better conditions for different groups to own their 

homes  without  compromising  financial  stability.  The  purpose  of  the  draft  amendments  is  also  to 

strengthen Sveriges Riksbank’s role in the macroprudential area.  

1.2  The  current  provisions  on  restrictions  on  mortgage  credits  are  set  out  in  certain  regulations  and 

general guidelines issued by Finansinspektionen (SFSA, Swedish Financial Supervisory Authority) 3. 

Pursuant to the referral, these provisions will now, with certain amendments which are the focus of 

this opinion as set out below, be regulated in law instead. In this respect, the Government considers 

that  issues  that  have  such  a  fundamental  impact  on  institutions’  lending  and  household  finances 

should, as a starting point, be regulated by law, as this strengthens democratic legitimacy 4. Further, 

the referral states that such regulation requires a certain degree of flexibility so that measures aimed 

at counteracting risks to financial stability are not delayed. In the Government's view, to the extent 

1 
2  

3 

4 

Sw. Lag (2014:966) om kapitalbuffertar. 

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, ELI: http://data.europa.eu/eli/dec/1998/415/oj). 

Finansinspektionens 
(FFFS  2016:16), 
Finansinspektionens allmänna råd om begränsning av krediter mot säkerhet i form av pant i bostad (FFFS 2016:33) 
and Finansinspektionens allmänna råd om undantag från amorteringskrav på grund av särskilda skäl (FFFS 2020:3). 

föreskrifter  om  amortering  av  krediter  mot  säkerhet 

i  bostad 

See Section 5.2 of the referral. 

 
 
 
 
 
 
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that  legislation  needs  to  be  supplemented  with  regulations  at  a  lower  level  than  primary  law,  this 

should be done by giving the Government the authority to issue regulations in this area 5. 

1.3  The draft law includes the following provisions in respect of the loan-to-value ratio and amortisation 

requirements 6: (a) upon granting a mortgage loan for a new house purchase, the creditor must limit 

the credit to ensure that the loan-to-value ratio does not exceed 90 %; (b) upon extending a mortgage 

loan, the creditor must limit the credit to ensure that the loan-to-value ratio does not exceed 80 %; 

and  (c)  the  Government  may  adopt  provisions  concerning  temporary  additional  limitations  on  the 

loan-to-value  ratio.  As  per  the  provisions  currently  in  place,  upon  granting  a  mortgage  loan,  the 

creditor must limit the credit to ensure that the loan-to-value ratio does not exceed 85 %, regardless 

of whether the mortgage is being granted or extended. The referral states that the current mortgage 

cap does not prevent high levels of debt, as the borrower can finance the purchase of the property 

in  other  ways,  for  example  with  their  own  savings  or  unsecured  loans.  The  mortgage  cap  may 
contribute  to  households  borrowing  less  and  buying  cheaper  homes.  For  households  that  do  not 

already own a home, the new mortgage cap would mean a lower threshold for entering the housing 

market. For households with strong repayment capacity due to good incomes but lower wealth, the 

mortgage cap means that credit space is limited if they are not prepared, or able, to supplement their 

mortgage  with  unsecured  credit.  Unsecured  loans  usually  entail  higher  interest  payments  and 

amortisation rates, which affects this group’s sensitivity to, for example, a loss of income7. As regards 

temporary  additional  limitations  on  the  loan-to-value  ratio,  such  tightening  measures  may  be 

implemented in the event of, for example, excessive credit growth that jeopardises financial stability. 

Such limitations are temporary in nature and the need for tightening measures should be reviewed 

on an ongoing basis, at least every 12 months 8. 

1.4  The draft law retains the existing amortisation requirement, whereby if the loan-to-value ratio exceeds 

50 % but not 70 %, the mortgage loan must be amortised annually by an amount equal to at least 1 

% of the total credit amount when  it was the  highest after the  most recent valuation (the ‘highest 

credit amount’), and if the loan-to-value ratio exceeds 70 %, the mortgage loan must be amortised 

annually by an amount equal to at least 2 % of the highest credit amount9.  

1.5  The draft law removes the current amortisation requirement, whereby the mortgage loan must be 

amortised by an additional 1 % annually of the highest credit amount if the amount of the aggregated 

mortgages of the borrower exceeds 4.5 times the borrower’s gross annual income. The Government 

considers  that  this  amortisation  requirement  risks  hindering  and  delaying  households  that  would 

otherwise have the means and income to enter the owner-occupied housing market. The fact that 

the requirement has contributed in part to a reduction in debt must be weighed against the fact that 

it excludes certain groups from being able to own their own homes10.  

5 
6  
7  
8  
9  
10  

See Section 5.2 of the referral. 
Sections 4, 5 and 6 of the draft law. 

See Section 5.1 of the referral. 
See Section 10.1 of the referral. 
Section 7 of the draft law. 

See Section 5.3.2 of the referral. 

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1.6  The  draft  law  retains  the  existing  regime,  whereby  upon  granting  a  mortgage  loan  for  a  newly 

constructed  residential  property,  the  creditor  may,  within  a  period  not  exceeding  five  years  from 

taking possession of the residential property, allow the credit not to be amortised in accordance with 

the draft law, provided that the debtor is the original buyer of the residential property. This also applies 

if the mortgage loan replaces credits utilised for financing the construction of the residential property 

and granted to the same debtor 11. 

1.7  The draft law provides that if the loan-to-value ratio does not exceed 50 %, the creditor must take 

steps to ensure that the mortgage will be amortised, with a view to maintaining a sound amortisation 

culture12.  This  does  not,  however,  necessarily  have  to  be  reflected  in  all  of  a  lender’s  mortgage 

agreements  as  there  is  no  requirement  for  actual  amortisation  or  a  minimum  amortisation  rate. 

Instead, it is up to the lender, in consultation with the borrower, to decide on amortisation based on 

the borrower's circumstances13.  

1.8  The  draft  law  provides  that  if  special  reasons  arise  during  the  maturity  of  the  mortgage  loan,  the 

creditor  may  allow  the  debtor  not  to  amortise  in  accordance  with  the  existing  amortisation 

requirement described in paragraph 1.4, within a limited period14. Special reasons may include, for 

example, the death of a close relative, unemployment, illness, divorce or parental leave 15.  

1.9  The draft law provides that in extraordinary circumstances which are likely to result in a particularly 

severe  recession,  the  Government  may  adopt  provisions  concerning  temporary  exemptions  from 

amortisation requirements16. One example is the situation observed in the COVID-19 pandemic. The 

need for temporary exemptions may be based on, for example, economic forecasts17. 

1.10  The draft law provides that for the purposes of calculating the loan-to-value ratio, the creditor must 

apply the market value valid at the time of purchase of the residential property. The creditor may also 

apply the market value determined at a later valuation date for the purposes of calculating the loan-

to-value ratio. Such a revaluation may be conducted at the earliest five years after either the purchase 

of the residential  property  or the most recent revaluation which resulted in the  amendment of the 

amortisation  amount  or  the  available  loan  amount.  If  the  market  value  of  the  residential  property 

changes  significantly  due  to  any  other  reason  than  the  overall  housing  price  development,  a 

revaluation may be conducted at an earlier date 18. 

1.11  The draft  amendments appoint Sveriges Riksbank as the authority responsible for calculating the 

buffer  guide  and setting countercyclical buffer rates, instead  of the  SFSA19. Sveriges Riksbank is 

given the right to set buffer values above 2.5 % and to identify and set countercyclical buffer values 

for  material  third  countries20.  The  draft  amendments  also  provide  that  Sveriges  Riksbank  is 

11  
12  
13  
14  
15  
16 
17  
18  
19  
20  

Section 11 of the draft law. 
Section 9 of the draft law. 

See Section 10.1 of the referral. 
See Section 5.3.4 of the referral and Section 10 of the draft law. 

See Section 10.1 of the referral. 
See Section 5.3.5 of the referral and Section 13 of the draft law. 

See Section 10.1 of the referral. 
See Section 5.5 of the referral and Section 14 of the draft law. 
Chapter 7, Section 1, of the amended Law on capital buffers. 

Chapter 7, Sections 3, 4 and 5, of the amended Law on capital buffers. 

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responsible for reporting decisions on countercyclical buffer rates to the European  Systemic Risk 

Board (ESRB)21. Sveriges Riksbank must consult with the SFSA before making such decisions 22, 

which may be appealed to the Administrative Court23. In addition, the SFSA should, according to the 

referral, give Sveriges Riksbank the opportunity to comment before the SFSA makes decisions in 

respect of capital-based macroprudential measures other than the countercyclical buffer values 24.  

1.12  The  macroprudential  policy  framework  in  Sweden  currently  assigns  the  SFSA  the  leading  role  in 

macroprudential supervision and designates the SFSA as the macroprudential authority. According 

to  the  explanatory  memorandum  accompanying  the  draft  law  (hereinafter  the  ‘explanatory 

memorandum’), the new division of responsibility between the SFSA and Sveriges Riksbank should 

be considered as implying that the SFSA no longer has the leading role in macroprudental policy in 

Sweden.  It  also  states  that,  in  these  circumstances,  the  conditions  for  maintaining  the  current 

exception from the main rule that the national central bank holds voting rights in the ESRB no longer 

applies. Against this background, the explanatory memorandum concludes that the voting rights in 

the ESRB should be transferred from the SFSA to Sveriges Riksbank and that it follows from this 

that Sveriges Riksbank should also be considered to be the designated authority in accordance with 
Recommendation ESRB/2011/3 of the European Systemic Risk Board 25, 26. 

1.13 

In summary, the referral states that in the light of the stability mandates and the various specialist 

competencies that exist at both the SFSA and Sveriges Riksbank, the Government considers that 

there is reason to review the division of responsibility for capital-based macroprudential measures 

between the two authorities. This is done partly in order to strengthen Sveriges Riksbank’s role in 

the  national  application  of  capital-based  macroprudential  measures,  with  the  aim  of  also  being 

assigned  a  crisis  prevention  tool,  and  partly  in  order  to  strengthen  the  authorities'  mutual 

responsibilities  with  regard  to  financial  stability  in  general  and  macroprudential  supervision  in 

particular 27.  The  Government  also  considers  it  important  to  assign  responsibility  for  the 

countercyclical buffer rate to Sveriges Riksbank. The Government considers that Sveriges Riksbank 

is particularly well suited for this task, not least in view of its mandate, which already requires a broad 

approach to analysing the economy, including the financial system and developments in the credit 

markets 28. 

21  
22  
23  
24  
25  

26  
27  
28  

Chapter 7, Section 8, of the amended Law on capital buffers. 

Chapter 7, Section 7a, of the amended Law on capital buffers. 
Chapter 11, Section 1, of the amended Law on capital buffers. 

See Section 6.4 of the referral. 
Recommendation ESRB/2011/3 of the European Systemic Risk Board of 22 December 2011 on the macro-prudential 
mandate of national authorities (OJ C 41, 14.2.2012, p. 1). 
See Section 7.3 of the referral. 
See Section 6.2 of the referral. 

See Section 6.3 of the referral. 

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2. 

Macroprudential role of Sveriges Riksbank  

2.1 

In its previous opinions on macroprudential oversight29 the ECB expressed support for the design of 

effective macroprudential policy frameworks within Member States, in line with the guiding principles 

set out in Recommendation ESRB/2011/3. It should be highlighted that the ESRB recommends that 

national  central  banks  should  have  a  leading  role  in  macroprudential  oversight  because  of  their 

expertise and their existing responsibilities in the area of financial stability 30. The ECB takes note 

that this principle is also indicated by Regulation (EU) No 1092/2010 of the European Parliament and 

of the Council31.  

2.2  Against  this  backdrop,  the  ECB  welcomes  the  strengthened  role  of  Sveriges  Riksbank  in  the 

macroprudential field, in particular the assignment to Sveriges Riksbank of responsibility for setting 

countercyclical buffer rates.  

2.3  At the same time, the ECB is mindful of the fact that, with the exception of the countercyclical capital 

buffer, the rest of the capital-based measures remain with the SFSA. This includes, for instance, the 

systemic risk buffer, both the general and the sectoral systemic buffer, which can be used to target 

cyclical risks that are otherwise not covered by the countercyclical capital buffer. This separation of 

responsibilities  for  the  capital-based  instruments  may  introduce  complexity  and  may  give  rise  to 

unwarranted overlaps and/or unaddressed risks due to the interactions between the instruments. In 

this  context,  the  ECB  stresses  that  it  is  important  to  have  in  place  mechanisms  for  cooperation, 

coordination and information exchange between the two authorities in order to ensure an effective 

implementation of macroprudential policies. This is also important to ensure, to the extent possible, 

a holistic view of overall capital requirements for banks in Sweden. In this respect, the ECB welcomes 

that  the  draft  law  requires  Sveriges  Riksbank  to  consult  the  SFSA  on  decisions  relating  to  the 

countercyclical capital buffer, and that the referral envisages that the SFSA consults with Sveriges 

Riksbank on decisions concerning other capital-based measures. 

2.4  The ECB welcomes the reinforcement of Sveriges Riksbank’s role in the ESRB, in terms of obtaining 

voting  rights  in  the  ESRB  and  being  considered  designated  authority  in  accordance  with 

Recommendation ESRB/2011/3. The separation of capital-based instruments implies that Sveriges 

Riksbank is assigned the responsibility for setting countercyclical buffer rates while the rest of the 

capital-based macroprudential tools remain the responsibility of the SFSA. Meanwhile, the borrower-

based measures directed towards households will now be regulated in law. The ECB accordingly 

notes that in effect these changes may give rise to uncertainty as to which authority will have the 

main responsibility for macroprudential policy in Sweden.  

29  

30  
31  

See, for example, paragraph 2.1 of Opinion CON/2013/82, paragraph 2.1 of Opinion CON/2022/8 and paragraph 3.1.3 
of Opinion CON/2024/11. All ECB opinions are published on EUR-Lex. 

See, for example, paragraph 3.1.3 of Opinion CON/2024/11. 
See recital 24 of Regulation (EU) No 1092/2010 of the European Parliament and of the Council of 24 November 2010 
on European Union macro-prudential oversight of the financial system and establishing a European Systemic Risk 
Board (OJ L 331, 15.12.2010, p. 1, ELI: http://data.europa.eu/eli/reg/2010/1092/oj). 

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3. 

Amendments to the framework for borrower-based measures in Sweden 

3.1  Regulation of borrower-based measures by law 

3.1.1  The draft law proposes to change the current regulatory framework for borrower-based measures in 

Sweden. Currently, it is the SFSA that initiates the measures, either introducing a new measure or 

adjusting  an  existing  one.  Based  on  its  analysis  and  assessment  of  the  systemic  risks  in  the 

residential real estate market and of the appropriate instrument to target the identified risks, it either 

drafts  a  proposal  for  a  regulation  or  for  a  general  recommendation.  Before  the  SFSA  issues  the 

appropriate  instrument,  it  must  obtain  the  government’s  consent  with  the  aim  of  anchoring  the 

measures democratically. As noted in paragraph 2.4, the borrower-based measures directed towards 

households will now be regulated by law. This amendment of the current framework risks conflicting 

with  the  recommendation  set  out  in  Recommendation  ESRB/2011/3  that,  in  the  pursuit  of  its 

objective, the macroprudential authority is as a minimum operationally independent, in particular from 

political bodies 32. Furthermore, Recommendation  ESRB/2011/3 recommends that Member States 

should  ensure  that  the  macroprudential  authority  has  control  over  appropriate  instruments  for 

achieving  its  objectives  and  that  where  necessary,  clear  and  expeditious  procedures  should  be 

established for assigning instruments to the macroprudential authority 33.  

3.1.2  The  ECB  refrains  from  making  any  further  observations  regarding  the  possible  institutional 

implications arising from regulating borrower-based measures directed towards households by law 

rather than by regulation issued by the SFSA34. Nevertheless, the ECB emphasises that the Swedish 

Government should ensure that it has the capacity to act in a flexible and proportionate way when 

setting and calibrating borrower-based measures for households. In this context, the ECB stresses 

the  importance  of  the  availability  of  a  comprehensive  set  of  borrower-based  measures,  including 

income-based measures. These measures are key to effectively and efficiently addressing potential 

risks to financial stability. 

3.2  Changes in the calibration of the borrower-based measures 

3.2.1  As noted in paragraph 1.3, the draft law proposes to ease some of the borrower-based measures 

currently  in  place  in  Sweden.  Notably,  the  loan-to-value  limit  for  new  house  purchases  would  be 

raised from 85 % to 90 %, whereas the limit for an extension on a mortgage would be lowered to 80 

%. At the same time, the amortisation requirement linked to borrowers’ income, whereby mortgages 

in excess of 4.5 times their gross income must be amortised with an additional 1 % annually, would 

be abolished.  

32  

33  

34  

See  Section  1,  Recommendation  E,  of  Recommendation  ESRB/2011/3.  See  also  paragraphs  3.1.3  and  3.1.4  of 
Opinion CON/2024/11, and paragraphs 2.1 and 2.2 of Opinion CON/2025/31. 

See  Section  1,  Recommendation  C,  of  Recommendation  ESRB/2011/3.  See  also  paragraph  2.2  of  Opinion 
CON/2025/31. 
See paragraph 2.3 of Opinion CON/2017/14, paragraph 2.3 of Opinion CON/2017/29 and paragraph 2.3 of Opinion 
CON/2018/30. 

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3.2.2  Recommendation  ESRB/2019/9  of  the  European  Systemic  Risk  Board35  identified  a  number  of 

medium-term vulnerabilities in Sweden’s residential real estate sector. In its assessment published 

in February 202236 and in the follow-up published in February 202437, the ESRB was of the view that 

vulnerabilities remained high in Sweden’s residential real estate market. Key vulnerabilities included 

high household indebtedness, house price overvaluation, high house price growth, high mortgage 

lending growth, a large proportion of non-amortising mortgages in the stock of existing mortgages 

and a high degree of interconnectedness with the Nordic banking system. Although there has been 

a  decrease  in  both  house  prices  and  household  debt  as  a  share  of  GDP  since  2022,  the  ESRB 

assessed that vulnerabilities still persist and remain high as household indebtedness is still among 

the highest in the Union. Against this background, the ESRB assessed that the current policy mix in 

Sweden  is  appropriate  and  partly  sufficient.  The  authorities  were  recommended  to  continue 

monitoring  vulnerabilities  and,  in  particular,  to  consider  introducing  measures  that  would  limit 

borrowing by overindebted households (e.g. a debt-to-income limit). 

3.2.3  From  a  financial  stability  perspective,  more  lenient  borrower-based  measures  could  lead  to  an 

increase in the demand for larger mortgages, potentially  contributing to higher house prices. This 

could  in  turn  contribute  to  increased  levels  of  household  indebtedness  and  make  housing  less 

affordable for low income households. In the specific case of Sweden, both Sveriges Riksbank 38 and 

the  SFSA39  have  highlighted  in  their  recent  financial  stability  assessments  that  household 

indebtedness remains high from an international perspective. This is the case despite the fact that 

currently both  house  prices and household debt  are  growing at a subdued  pace. Both  authorities 

have expressed concerns that the proposed easing of the mortgage regulations risk leading to debt 

and house prices growing again in a way that is not sustainable in the long term.  

3.2.4  In its statement issued in July 202540, the ECB’s Governing Council emphasised the importance of 

maintaining the resilience of the banking system, especially in the light of the sharp rise in global 

geopolitical uncertainty. While this statement concerned euro area countries, the context for Sweden 

is similar. In the same statement, the ECB’s Governing Council called on national macroprudential 

authorities to maintain the current resilience of the banking system, with regard to maintaining both 

capital buffer requirements and measures taken in the real estate sector. With particular regard to 

the  latter,  it  reiterated  that  existing  borrower-based  measures  should  be  maintained  to  preserve 

sound and sustainable lending standards via their role as structural backstops. 

3.2.5  Against  this  background,  and  as  noted  in  the  ECB’s  Governing  Council  statement  of  July  2025, 

macroprudential policy needs to remain agile and adaptable to changing conditions, in view also of 

the high level of uncertainty. The ECB invites policymakers in Sweden to continue monitoring closely 

35  

36  

37  

38  
39  
40  

Recommendation ESRB/2019/9 of the European Systemic Risk Board of 27 June 2019 on medium-term vulnerabilities 
in the residential real estate sector in Sweden (OJ C 366, 30.10.2019, p. 35). 

‘Vulnerabilities in the residential real estate sectors of the EEA countries’, ESRB, February 2022, published on the 
ESRB’s website at www.esrb.europa.eu. 

Follow-up report on vulnerabilities in the residential real estate sectors of the EEA countries, ESRB, February 2024, 
published on the ESRB’s website at www.esrb.europa.eu. 

See Sveriges Riksbank, Financial stability report, 2025:2. 
See Finansinspektionen, Stability in the Financial System, 2025:2. 
See ECB, Governing Council statement on macroprudential policies, 7 July 2025, available on the ECB’s website at 
www.ecb.europa.eu.  

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the developments of financial stability risks in the residential real estate sector and stand ready to 

adjust the borrower-based measures, as further adverse shocks may require timely changes in the 

policy stance. 

This opinion will be published on EUR-Lex. 

Done at Frankfurt am Main, 6 February 2026. 

[signed] 

The President of the ECB 

Christine LAGARDE 

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