Opinion of the European Central Bank of 17 June 2026 on the functioning of a Systemic Stability Council (CON/2026/19)
Date: 2026-06-17
Institutions: European Central Bank
Subjects: financial stability

ECB-PUBLIC 

EN 

OPINION OF THE EUROPEAN CENTRAL BANK 

of 17 June 2026  

on the functioning of a Systemic Stability Council 

(CON/2026/19) 

Introduction and legal basis 

On 11 May 2026 the European Central Bank (ECB) received a request from the Greek Ministry of National 

Economy and Finance for an opinion on draft amendments (hereinafter the ‘draft amendments’) to Article 

20  (hereinafter  the  ‘original  provision’)  of  Law  No  3867  of  2010  on  private  insurance  supervision,  the 

establishment of a private life insurance guarantee fund, credit rating agencies and other provisions falling 

within the competence of the Ministry of Finance1 (hereinafter the ‘draft amendments’). 

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 indent, of Council Decision 98/415 2, as the draft 

amendments  relate  to  (1)  the  Bank  of  Greece  and  (2)  the  European  System  of  Central  Banks’  task  to 

contribute  to  the  smooth  conduct  of  policies  by  the  competent  authorities  relating  to  the  stability  of  the 

financial system pursuant to Article 127(5) of the Treaty. 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 amendments 

1.1  The  draft  amendments  restate  and  amend  the  original  provision,  which  sets  out  the  institutional 

framework,  mandate,  composition  and  powers  of  the  Systemic  Stability  Council  (hereinafter  the 

‘Council’). 

1.2  According to the explanatory memorandum, the draft amendments have been proposed with a view 

to (1) ensuring the  proper  functioning of the Council  and compliance with the principles  of sound 

administration and effectiveness, and (2) strengthening the  institutional framework for supervision 

and the management of systemic risks in the financial sector by facilitating faster and more informed 

assessments  of  information,  continuous  monitoring  of  market  developments  and  the  prompt 

submission of recommendations to the Council by two new subcommittees. 

1.3  The draft amendments restate that the Council is established within the Ministry of National Economy 

and  Finance  and  that  its  mandate  comprises  the  responsibility  to  analyse  the  interaction  and 

dynamics  among  the  various  systems  of  the  financial  sector  and  to  continuously  explore 

precautionary measures for addressing emergency or extreme situations and crises. In particular, 

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2  

Ν. 3867/2010 «Εποπτεία Ιδιωτικής Ασφάλισης, Σύσταση εγγυητικού κεφαλαίου ιδιωτικής ασφάλισης ζωής, οργανισμοί 
αξιολόγησης  πιστοληπτικής  ικανότητας  και  άλλες  διατάξεις  αρμοδιότητας  του  Υπουργείου  Οικονομικών»,  ΦΕΚ  Α 
128/03.08.2010.  
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). 

 
 
 
 
 
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the Council: (1) monitors the relationship and dynamics among the systems of the economy, with 

particular emphasis on capital markets, the banking and insurance systems, liquidity, public debt and 

government guarantees, as well as on precautionary actions against extreme situations, instability 

and crises; (2) monitors the financial policy of the Ministry of National Economy and Finance and the 

needs related to financial stability, submits relevant recommendations, and examines issues arising 

within the framework of the functioning of  the  European supervisory institutions; and (3) monitors 

and ensures the exchange of information between the Ministry of National Economy and Finance 

and the national independent supervisory authorities of the financial sector, in order to coordinate 

the financial policy of the Ministry of National Economy and Finance. 

1.4  The draft amendments also restate the composition of the Council, which consists of the following 

eight  members:  (1)  the  Minister  for  National  Economy  and  Finance,  (2)  the  Deputy  Minister  for 

National  Economy  and  Finance  or,  where  no  Deputy  Minister  has  been  appointed,  the 

Undersecretary  of  State  for  Fiscal  Policy,  (3)  the  Secretary-General  for  the  Financial  Sector  and 

Private  Debt  of  the  Ministry  of  National  Economy  and  Finance,  (4)  the  Secretary-General  for 

Economic Policy and Strategy of the Ministry of National Economy and Finance, (5) the Governor of 

the  Bank  of  Greece,  (6)  the  Deputy  Governor  of  the  Bank  of  Greece  responsible  for  the  relevant 

subject matter, (7)  the Chair of the Hellenic Capital Market Commission, and (8) the Chair  of the 

Public Debt Management Agency. The Chair of the Council is the Minister for National Economy and 

Finance, and is replaced by the Deputy Minister for National Economy and Finance, or, if no Deputy 

Minister has been appointed, by the Secretary-General for the Financial Sector and Private Debt of 

the Ministry of National Economy and Finance. In the event of a tie, the Chair is to have the casting 

vote. 

1.5  The draft amendments require the Council to be convened at least once per year. 

1.6  The draft amendments establish two subcommittees within the Council, namely a Crisis Management 

Committee and a Systemic Stability Committee, whose members each consist of the Director of the 

Financial Policy Directorate of the General Secretariat for the Financial Sector and Private Debt of 

the Ministry of National Economy and Finance, as well as designated representatives of the Bank of 

Greece,  the  Hellenic  Capital  Market  Commission  and  the  Hellenic  Deposit  and  Investment 

Guarantee  Fund.  The  draft  amendments  provide  that  these  subcommittees  assume,  on  a 

proportional basis, the responsibilities of the Council and its monitoring tasks. They meet every six 

months  and,  following  each  meeting,  submit  an  informational  memorandum  to  the  Chair  of  the 

Council. 

1.7  The draft amendments give the right to the Chair of the Hellenic Deposit and Investment Guarantee 

Fund to attend, upon invitation of the Chair of the Council, and without voting rights, the Council’s 

meetings. This is in addition to the same possibility currently given by the original provision to other 

officials such as governors, chairs or chief executive officers of credit institutions, specialised experts, 

and any other third party whose opinion the Chair of the Council considers would assist the Council’s 

work.  

1.8  The  draft  amendments  restate  that  the  Chair  and  the  Chief  Executive  Officer  of  the  Hellenic 

Corporation  of  Assets  and  Participations  (HCAP)  is  to  be  mandatorily  invited  to  meetings  of  the 

Council where the discussion concerns credit institutions’ share capital in which the HCAP holds a 

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participation. The resolution authority is to be mandatorily invited for matters relating to resolution 

and  is  to  participate  in  meetings  without  voting  rights,  represented  by  a  person  other  than  those 

designated to represent the relevant supervisory authority. 

1.9  The  draft  amendments  also  replace  the  wording  of  the  title  as  well  as  that  which  relates  to  the 

capacity  of  certain  members  of  the  Council  to  reflect  organisational  and  institutional  updates  that 

have occurred within the respective bodies to whom these members belong.  

2. 

General observations 

2.1  The  ECB  was  consulted  and  adopted  an  opinion  on  a  draft  version  of  the  original  provision 

establishing the Council in 2010 3. The ECB understands that the Council has largely been inactive 

since its establishment, and that the draft amendments are essentially intended to operationalise the 

Council.  

2.2  The ECB notes that, since 2014, the Bank of Greece is the macroprudential authority responsible in 

Greece  for  the  adoption  of  the  combined  buffer  requirement,  the  adoption  of  borrower-based 

measures and other macroprudential instruments 4. 

2.3  The ECB in principle welcomes that all the relevant authorities and institutions involved in matters 

related to financial stability in Greece are represented in the Council5, to the extent that this increases 

effective policy coordination.  

2.4  As pointed out in previous opinions, the establishment of national financial stability committees may 

enhance the ability of national central banks (NCBs) and supervisory authorities to provide analytical 

support  to  the  European  Systemic  Risk  Board  (ESRB)6.  However,  it  is  necessary  to  avoid  such 

national committees being entrusted with tasks and powers that potentially conflict with those of the 

ESRB  and  which  may  undermine  its  effectiveness.  Moreover,  the  legal  frameworks  of  these 

committees should appropriately reflect the NCBs’ roles, should not constrain the independence of 

their governors or unduly affect the quality and impartiality of their contributions as members of the 

ESRB, and should take account of the ECB’s macroprudential supervisory powers in the context of 

the Single Supervisory Mechanism. Lastly, in view of the importance of ensuring the effectiveness of 

macroprudential supervisory arrangements at Union level, it  is essential to safeguard the ESRB’s 

ability to perform its tasks independently and to guarantee an authoritative and effective channel for 

transmitting its warnings and recommendations. Against this background, it is important that the draft 

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5  

6  

See paragraph 1.3 and paragraph 5 of Opinion CON/2010/33. All ECB opinions are published on EUR-Lex. 

According  to  Law  4261/2014  on  access  to  the  activity  of  credit  institutions  and  prudential  supervision  of  credit 
institutions and investment firms (transposing Directive 2013/36/EU), repeal of Law 3601/2007, and other provisions 
(Government Gazette A, 107/05.05.2014) (N. 4261/2014 «Πρόσβαση στη δραστηριότητα των πιστωτικών ιδρυμάτων 
και  προληπτική  εποπτεία  πιστωτικών  ιδρυμάτων  (ενσωμάτωση  της  Οδηγίας  2013/36/ΕΕ),  κατάργηση  του  νόμου 
3601/2007 και άλλες διατάξεις», ΦΕΚ Α, 107/05.05.2014; and articles 2, 55Α και 55C of the Statute of the Bank of 
Greece ratified by Law 3424/1927 (Government Gazette A, 298/7.12.1927) (Ν. 3424/1927 «Περί κυρώσεως του από 
10 Νοεμβρίου 1927 ΝΔ/τος ''Περί κυρώσεως της από 27 Οκτωβρίου 1927 συμβάσεως περί παραιτήσεως της Εθνικής 
Τραπέζης της Ελλάδος από του προνομίου εκδόσεως τραπεζικών γραμματίων και περί συστάσεως νέας Τραπέζης 
υπό την επωνυμίαν «ΤΡΑΠΕΖΑ ΤΗΣ ΕΛΛΑΔΟΣ» και του προσαρτωμένου τη συμβάσει Καταστατικού της Τραπέζης 
της Ελλάδος''», ΦΕΚ Α, 298/7.12.1927).  
See,  for  example,  paragraphs  9  and  10  of  Opinion  CON/2002/13,  paragraph  2.1  of  Opinion  CON/2019/10  and 
paragraph 2.1 of Opinion CON/2023/32 ; see also International Monetary Fund’s Staff Concluding Statement of the 
2026 Article IV Consultation Mission of 24 March 2026, available at www.imf.org. 
See  paragraph  2.1  of  Opinion  CON/2010/3,  paragraph  2.2.2  of  Opinion  CON/2010/7,  paragraph  2.11  of  Opinion 
CON/2010/10, paragraphs 5.1 and 5.2 of Opinion CON/2010/33 and paragraph 4 of Opinion CON/2012/106. 

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amendments  ensure  that  the  Council  will  function  in  a  way  that  is  fully  consistent  with  the 

abovementioned principles. 

2.5 

In line with previous opinions7, it is equally important that the tasks attributed to the Council do not 

undermine (1) the Bank of Greece’s institutional independence, or (2) the performance by the Bank 

of Greece of its ESCB-related tasks under the Treaty and the Statute of the European System of 

Central Banks and of the European Central Bank. The draft amendments should ensure that these 

aspects are clearly dealt with.  

2.6 

In that context, the draft amendments should also clearly set out that the Council’s recommendations 

for issues related to financial stability are only to be made to the Ministry of National Economy and 

Finance, so that the Bank of Greece’s independence as macroprudential authority is ensured.  

2.7  Moreover,  the  draft  amendments  should  ensure  that  the  exercise  by  the  Council  of  its  task  of 

monitoring and ensuring the exchange of information between the Ministry of National Economy and 

Finance  and  the  national  independent  supervisory  authorities  of  the  financial  sector  is  without 

prejudice  to  professional  secrecy  requirements  and  provisions  ensuring  the  confidentiality  of 

information received by the Bank of Greece in the course of its duties, which the Bank of Greece 

must adhere to itself 8.  

This opinion will be published on EUR-Lex.  

Done at Frankfurt am Main, 17 June 2026. 

[signed] 

The President of the ECB 

Christine LAGARDE 

7  

8  

See, for example, paragraph 11 of Opinion CON/2002/13, paragraph 4 of Opinion CON/2009/88, paragraph 3.1 of 
Opinion CON/2010/4, paragraph 2.2.4 of Opinion CON/2010/7, paragraph 2.9 of Opinion CON/2010/10, paragraph 
3.2  of  Opinion  CON/2012/55,  paragraph  2.3  of  Opinion  CON/2013/30,  paragraph  2.2  of  Opinion  CON/2013/45, 
paragraph  2.3  of  Opinion  CON/2013/69,  paragraph  2.2  of  Opinion  CON/2013/70  and  paragraph  3.1.2  of  Opinion 
CON/2014/18.  

See also paragraph 5.2 of Opinion CON/2010/33. 

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