Οι περισσότερες τράπεζες κινήθηκαν κατά της σχετικής κοινοποίησης των ΕΑΕ (34), καθώς αυτή αποτελεί τη νομική βάση για την καταβολή τους. Ως εκ τούτου, στις 21 Ιουνίου 2019, εκκρεμούσαν σε εθνικό επίπεδο 625 διοικητικές ή ένδικες διαδικασίες κατά των εκ των προτέρων εισφορών. Ωστόσο, δεδομένου ότι οι εισφορές υπολογίζονται και καθορίζονται από το (34) Ανάλογα με το νομικό πλαίσιο στα συμμετέχοντα κράτη μέλη, οι ΕΑΕ ειδοποιούν τις τράπεζες μέσω διοικητικών πράξεων, αποφάσεων ή κοινοποιήσεων. 
EN 22 1 2020 Official Journal of the European Union C 22/17 at national level, as of 21 June 2019 However, as the contributions are calculated and set by the SRB, applicants have also brought court proceedings at the CJEU against the SRBŐs decisions on ex-ante contributions for the years 2016 to 2018 As of 21 June 2019, 16 proceedings were pending While 15 of them were pending at the GC, one case was an appeal to a ruling of the GC pending at the CJ In addition, there was a request from a national court asking for a preliminary ruling of the CJ on the interpretation of EU law related to ex-ante contributions (35) However, the action has not been taken against the SRB 42 As outlined above, the system established to calculate and collect ex-ante contributions for the SRF includes shared responsibilities between the EU and Member States The legal actions against ex-ante contributions therefore raise the difficult issue of judicial review of the SRBŐs decisions regarding contributions to the SRF (36) The SRB stated in the past that it is not yet clear whether applicants can bring legal proceedings against ex-ante contributions at European level The Advocate General stated in an opinion delivered in case C-414/18 on 9 July 2019 that, based on case law, national courts cannot rule on the lawfulness of decisions adopted by the SRB, such as the SRBŐs decision on ex-ante contributions, and that the CJEU has exclusive competence in that matter (37) However, only a final judgment of the CJ can bring legal certainty In the absence of such a judgment, our working assumption for this report is that a potential outflow of resources can result from administrative and court proceedings at national level brought against legal acts of NRAs, as well as from legal proceedings at EU level brought against legal acts of the SRB concerning ex-ante contributions to the SRF 43 In its final annual accounts for 2018, the SRB disclosed contingent liabilities arising from ex-ante contributions due to pending judicial proceedings at the GC The SRB assessed that there are contingent liabilities of Ű50 million relating to seven cases (38) For additional transparency, the SRB disclosed that ex-ante contributions amounting to Ű222,7 million in total had been challenged in the CJEU at the end of 2018 44 An adequate knowledge of the financial risks to which the SRB is exposed is essential to ensure appropriate risk management and accounting Based on our 2018 recommendations, the SRB improved its internal control system on contingent liabilities arising related to ex-ante contributions from court cases at national level The SRB asks NRAs to provide a detailed list of ongoing proceedings against ex-ante contributions In addition, NRAs are asked to give written assurance on the information provided and to provide an assessment of the likelihood of the success of the proceedings against ex-ante contributions 45 Based on the information received from NRAs, administrative and judicial proceedings have been brought against contribution decisions made by four NRAs However, three of the four NRAs concerned stated that they are not in a position to assess the likelihood of a successful outcome of ongoing proceedings, given the uncertainties described in paragraph 42 and as there is not yet any related case law Only one NRA provided the SRB with a detailed assessment, concluding that the outflow of resources as the result of a case was not remote While the SRB disclosed contingent liabilities of Ű40 million related to the proceedings at national level based on this NRA assessment (39), it did not disclose any contingent liabilities related to the cases in the three Member States where the NRAs claimed that they were not in a position to make an assessment 46 We note that assessment of the exact amounts at risk is complicated In this regard, the SRBŐs accounting presentation of contingent liabilities related to ex-ante contributions represents an improvement in comparison to previous years where it simply presented the entire amounts challenged as contingent liabilities without any assessment of specific cases Based on the evidence reviewed from the SRB, we conclude that the SRB made reasonable attempts to ascertain whether these cases represented contingent liabilities, and reported them fairly 47 In addition to disclosing contingent liabilities related to ex-ante contributions, the SRB disclosed the total amounts of ex-ante contributions, which are subject to administrative or judicial proceedings They amount to around Ű2 billion, of which Ű1,8 billion are related to national cases and Ű222,7 million are related to cases at the GC (see Table 4) While only a small part of these amounts might ever have to be reimbursed to applicants and would be offset by future ex-ante contributions from all banks under the SRBŐs remit, this disclosure provides useful background information for stakeholders (35) Based on Article 267 TFEU, preliminary rulings can be requested by courts of Member States to interpret EU law (36) Opinion of Advocate General Campos Snchez-Bordona delivered in case C-414/18 on 9 July 2019, point 26 (37) Opinion of Advocate General Campos Snchez-Bordona delivered in case C-414/18 on 9 July 2019, points 29-31 (38) SRB Annual Accounts, p 34 (39) SRB Annual Accounts, p 33