Implementing CRD V and the EU banking package with confidence

CRD V Implementation & EU Banking Package

The Capital Requirements Directive V (Directive 2019/878) and its national implementation introduce comprehensive regulatory requirements for credit institutions — from MREL and TLAC to stricter remuneration rules and enhanced proportionality frameworks.

  • 01Compliance architectures for CRD V requirements
  • 02Digital governance with machine learning optimization
  • 03Automated supervisory interaction
  • 04Predictive risk management systems for modern banking
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CRD V – Capital Requirements Directive V Requirements for Credit Institutions

The Capital Requirements Directive V (CRD V, Directive 2019/878/EU) amended the European CRD IV in 2019 and transposed key elements of the Basel III reforms into EU law. CRD V tightens requirements for governance, remuneration policy and fit-and-proper assessments, introduces the proportionality principle for smaller institutions and establishes a harmonised third-country regime for non-EU branches.

We support credit institutions and investment firms in the complete implementation of CRD V requirements – from governance analysis through remuneration policy to preparation for the CRD VI transition. Our consulting approach combines deep regulatory expertise with proven implementation methods.

6 service modules

What we take on for you

Bookable individually or as an end-to-end programme.

01

Digital Compliance Architectures and Automated CRD V Implementation

We develop compliance architectures for implementing CRD V standards and create intelligent systems for fully automated compliance orchestration in the digital banking era.

  • Analysis of CRD V innovations and digitalization requirements
  • Automated compliance orchestration for modern banking supervision
  • Digital transformation with continuous CRD V optimization
  • Predictive analysis of regulatory trends and proactive compliance adaptation
02

Modern Governance Frameworks and Supervisory Interaction

Our platforms create adaptive modern governance structures with continuous digital supervisory monitoring and automated RegTech integration.

  • Modern governance structure optimization
  • Real-time monitoring of all CRD V compliance parameters
  • Automated digital supervisory communication and intelligent reporting
  • Intelligent adaptation of governance processes to CRD V innovations
03

Modern Fit and Proper Systems and Digital Suitability Assessments

We implement intelligent systems for modern fit and proper assessments with data-driven analysis and continuous digital monitoring for the CRD V era.

  • Automated fit and proper analysis with digital assessment logic
  • Data-driven risk assessment of executives
  • Continuous digital monitoring and early detection
  • Intelligent digital documentation and automated evidence management
04

Digital Risk Management Integration and Optimization

We develop intelligent digital risk management systems that combine CRD V requirements with advanced technology for optimal modern risk control.

  • Integration of digital risk management into modern governance
  • Data-driven digital risk identification and assessment
  • Intelligent modern risk strategy development and monitoring
  • Automated digital risk reporting and modern supervisory communication
05

Fully Automated Digital Compliance Monitoring and Reporting

Our platforms automate CRD V compliance monitoring with intelligent digital reporting and continuous RegTech optimization.

  • Fully automated digital monitoring of all CRD V compliance requirements
  • Modern report generation and supervisory communication
  • Intelligent digital early detection of compliance deviations and risks
  • Digital process improvement and continuous compliance evolution
06

Digital Change Management and RegTech Integration

We support you in the intelligent digital transformation of your CRD V compliance and in building sustainable RegTech innovation capabilities.

  • Digital change management strategies for CRD V transformation
  • Development of internal CRD V expertise and RegTech innovation competence centres
  • Tailored digital training programmes for modern banking supervision
  • Continuous innovation and adaptive digital regulatory support

5 phases

Our CRD V Consulting Approach

We guide institutions through CRD V compliance in a structured manner – from regulatory stocktake to implementation and ongoing monitoring. We always consider the interactions with CRR II, MaRisk and the upcoming CRD VI requirements.

  1. Regulatory stocktake

    comparison of your current governance, remuneration and suitability processes against CRD V requirements

  2. Gap analysis and prioritisation

    identification of action items and development of a risk-based implementation plan

  3. Implementation

    adaptation of policies, processes and documentation to CRD V standards

  4. Supervisory interaction

    support with notification procedures, fit-and-proper evidence and regulatory dialogues

  5. Ongoing monitoring and CRD VI readiness

    tracking regulatory developments and proactive adaptation

Your contact

Melanie Düring

Head of Risk Management

+49 69 913 113-01 info@advisori.de
CRD V represents a fundamental shift in EU banking regulation and opens up unprecedented opportunities for digital innovation and technology integration. Our advanced RegTech solutions enable institutions not only to meet the new regulatory standards but also to establish technological leadership in the digital banking era. By combining deep regulatory expertise with advanced technologies, we create sustainable digital advantages while protecting critical corporate data.

Why ADVISORI for Your CRD V Compliance

  • 01Extensive experience implementing CRD IV, CRD V and CRR II at banks, investment firms and financial services providers
  • 02Proven methodology for governance reviews, remuneration analysis and fit-and-proper procedures
  • 03Integrated approach: CRD V assessed in the context of CRR II, MaRisk, EBA guidelines and upcoming CRD VI
  • 04Direct supervisory and BaFin experience for practical interpretation of requirements

CRD V Fully in Force – CRD VI Already Adopted

CRD V has been transposed into national law since December 2020 and together with CRR II forms the current regulatory baseline. With the adoption of CRD VI (Directive 2024/1619) in 2024, further tightening of ESG risk requirements, third-country branch rules and governance is imminent. Institutions must review existing CRD V structures for CRD VI readiness now.

7 QUESTIONS, BRIEFLY ANSWERED

Frequently asked questions about CRD V Implementation & EU Banking Package

What is CRD V and what requirements does it impose on credit institutions?

CRD V (Directive 2019/878/EU) is the fifth iteration of the European Capital Requirements Directive and amends CRD IV from 2013. It transposes key Basel III reforms into EU law and tightens requirements in particular for:

• Governance: composition, suitability and diversity of management bodies (Art. 88, 91 CRD)
• Remuneration: stricter caps on variable pay for material risk takers and expanded disclosure obligations (Art. 92–95 CRD)
• Fit and proper: expanded suitability assessments for directors, supervisory board members and key function holders
• Proportionality: reliefs for small and non-complex institutions in reporting and disclosure
• Intermediate EU Parent Undertaking (IPU): obligation for non-EU banking groups with material EU presence to establish an intermediate EU parent

CRD V entered into force on 27 June 2019 and had to be transposed into national law by 28 December 2020.

What governance changes does CRD V introduce compared to CRD IV?

CRD V tightens CRD IV governance requirements in several areas:

• Management bodies: stricter requirements for board composition, including diversity targets and limits on the number of directorships
• Internal control functions: clearer separation and strengthening of compliance, risk management and internal audit
• Risk management: obligation to establish a risk committee at management body level for systemically important institutions
• Supervisory dialogue: enhanced cooperation between competent authorities and institutions on governance matters

Institutions must assess whether their existing governance structures meet CRD V standards – particularly regarding the composition and qualification of management bodies.

What does proportionality mean under CRD V and which institutions benefit?

CRD V introduces a formalised proportionality principle that grants regulatory reliefs to small and non-complex institutions. Classification as a small/non-complex institution under Art. 4(1)(145) CRR II depends on criteria such as total assets (below EUR 5 billion), trading book activity and business model.

Reliefs cover among others:

• Simplified disclosure requirements with reduced reporting frequencies
• Reduced supervisory reporting obligations
• Simplified remuneration requirements where pay levels are lower
• Less extensive ICAAP/ILAAP documentation

ADVISORI assists institutions in assessing whether they qualify for proportionality reliefs and in deriving the applicable simplifications.

What does CRD V require regarding remuneration of material risk takers?

CRD V tightens CRD IV remuneration rules particularly for material risk takers:

• Bonus cap: the ratio of variable to fixed remuneration remains capped at 1:1 (with the possibility of increasing to 2:1 by shareholder approval)
• Risk taker identification: expanded criteria under Delegated Regulation (EU) 2021/923 for determining staff whose activities have a material impact on the risk profile
• Deferral and malus: at least 40% of variable remuneration must be deferred; for senior management at least 60%
• Proportionality waiver: small institutions may be exempted from certain remuneration requirements

ADVISORI advises on risk taker identification, remuneration policy adjustments and regulatory documentation.

What are the CRD V fit-and-proper requirements and how are they assessed?

CRD V expands the suitability (fit and proper) requirements for directors and supervisory board members under Art. 91 CRD:

• Professional competence: sufficient knowledge and experience for the respective function, including regulatory and banking expertise
• Good repute: no criminal convictions or measures that call personal integrity into question
• Time commitment: limits on the number of concurrent directorships to ensure effective oversight
• Collective suitability: the management body as a whole must cover all required knowledge and experience areas

Supervisory authorities assess suitability through formal notification procedures. ADVISORI supports the preparation of suitability evidence, supervisory interviews and ongoing compliance with fit-and-proper requirements.

What is the Intermediate EU Parent Undertaking (IPU) under CRD V?

CRD V introduces under Art. 21b the obligation to establish an Intermediate EU Parent Undertaking (IPU). Non-EU banking groups that have at least two subsidiaries in the EU (institutions or mixed financial holding companies) and whose total EU assets exceed EUR 40 billion must set up an intermediate EU parent company.

The IPU:

• Consolidates all EU subsidiaries under a single holding structure
• Is subject to consolidated supervision by an EU competent authority
• Facilitates resolution planning and crisis management for non-EU groups

Under CRD VI the third-country regime is further tightened, particularly through new licensing requirements for third-country branches.

How do CRD V, CRR II and the upcoming CRD VI relate to each other?

CRD V and CRR II together form the 2019 Banking Package and transpose the Basel III reforms into EU law:

• CRD V (Directive 2019/878): governance, remuneration, fit and proper, proportionality, third-country regime – must be transposed into national law
• CRR II (Regulation 2019/876): own funds requirements, leverage ratio, NSFR, MREL – directly applicable in all EU member states

The successors CRD VI (Directive 2024/1619) and CRR III (Regulation 2024/1623) were adopted in 2024 and introduce further tightening:

• CRD VI: ESG risk plan, expanded fit-and-proper rules, new third-country branch regime – transposition deadline 2026• CRR III: output floor, revised standardised approach for credit risk, FRTB – applicable from January 2025ADVISORI supports institutions across the full regulatory lifecycle from CRD IV through CRD V to CRD VI readiness.

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