Transparent escalation and efficient communication processes for regulatory requirements

EBA Escalation & Communication Structures

We support you in developing and implementing effective escalation and communication structures that ensure transparency, meet regulatory requirements and enable proactive management of critical situations.

  • 01Clear escalation pathways and decision-making processes for critical situations
  • 02Efficient internal and external communication structures
  • 03Improved transparency and traceability of regulatory decisions
  • 04Proactive management of risks and supervisory requirements
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11+Years of experience
120+Employees
540+Projects
ISO 27001certified

Escalation Framework and Communication in SREP 2.0

With SREP 2.0, the EBA fundamentally changes the logic of supervisory escalation: findings are classified by severity, measures are followed up more rigorously, and expectations regarding institutions' responsiveness and communication quality rise significantly from 2027. Banks therefore need robust internal escalation pathways, clear responsibilities, and professional communication with supervisors — from the structured response to findings through the ongoing supervisory dialogue to effective remediation governance.

We analyse your existing structures, design a target process aligned with the new EBA escalation framework, and embed it in committees, reporting, and crisis communication. The result: traceable decision-making paths, timely implementation of supervisory measures, and a confident position vis-à-vis the ECB and national supervisory authorities.

2 service modules

Service scope

01

Development of Escalation Structures

We support you in the conception and implementation of clear escalation pathways and decision-making processes for critical situations in the regulatory context.

  • Analysis of existing escalation pathways and identification of optimisation potential
  • Development of tailored escalation models with clear triggers and responsibilities
  • Implementation of early warning systems for potential regulatory risks
  • Establishment of transparent decision-making and documentation processes
02

Optimisation of Communication Structures

We support you in designing and implementing efficient internal and external communication processes for regulatory requirements.

  • Analysis of existing communication pathways and practices
  • Development of efficient internal communication structures with clear responsibilities
  • Optimisation of communication with supervisory authorities and external stakeholders
  • Implementation of transparent reporting and documentation structures

5 phases

Our Approach

We support you with a structured and proven approach to developing and implementing effective escalation and communication structures.

  1. Analysis of existing communication and escalation processes as well as regulatory requirements

  2. Development of a tailored concept for optimised escalation and communication structures

  3. Implementation of the defined structures with clear responsibilities and processes

  4. Training of employees and managers for the effective use of the new structures

  5. Continuous evaluation and optimisation of the implemented processes

Your contact

Melanie Düring

Head of Risk Management

+49 69 913 113-01 info@advisori.de
Effective escalation and communication structures are not only a regulatory requirement, but a strategic advantage. They enable financial institutions to respond proactively to risks, establish transparent decision-making processes and build a relationship of trust with supervisory authorities. Our clients benefit from our extensive experience in designing and implementing these critical structures.
ADVISORI expert opinion

7 QUESTIONS, BRIEFLY ANSWERED

Frequently asked questions about EBA Escalation & Communication Structures

What changes does the new EBA escalation framework bring under SREP 2.0 from 2027?

The new EBA escalation framework (EBA/CP/2025/21) replaces existing SREP guidelines from January 2027 and introduces a flexible, tiered escalation model. Supervisory authorities can select measures based on the severity and root cause of findings — ranging from informal dialogue through binding qualitative requirements to enforcement and sanctions. Crucially, the sequence is not a rigid sequential model but allows for situation-appropriate adaptation. Remediation governance — how quickly and effectively an institution addresses deficiencies — becomes a subject of supervisory assessment itself and influences supervisory intensity.

What are the EBA requirements for communicating SREP results to financial institutions?

The revised EBA guidelines establish mandatory minimum standards for SREP result communication for the first time. Supervisory authorities must consolidate results in a formal letter to the management body containing the overall SREP score, individual assessment elements, and key risk drivers. Pillar 2 requirements must be justified on an institution-specific basis. This increases transparency but also requires financial institutions to align their internal communication structures to relay this information promptly and accurately to relevant decision-makers.

What is remediation governance in the SREP context and why is it critical?

Remediation governance describes the systematic process by which a financial institution addresses supervisory findings: assigning ownership, defining milestones, verifying progress, and reporting to the management body. Under the new SREP framework, remediation governance itself becomes subject to supervisory assessment. This means how quickly and effectively an institution remedies deficiencies directly influences supervisory intensity and the choice of future measures. Institutions with weak remediation governance risk escalated supervisory actions.

How can banks prepare their escalation structures for SREP 2.0?

Preparation for the new escalation framework comprises four core steps: (1) Gap analysis — assess existing escalation processes against the new EBA requirements, particularly the findings severity model (F1-F4). (2) Governance mapping — define clear responsibilities, milestones, and reporting lines for each escalation level. (3) Implement early warning systems — establish proactive Key Risk Indicators (KRIs) that signal potential findings early. (4) Conduct test runs and training — simulate crisis scenarios to validate functionality under stress and optimise response times.

What role does supervisory dialogue play in the new SREP escalation framework?

The supervisory dialogue is being strategically enhanced under SREP 2.0. Banks will be informed earlier about supervisory concerns and potential findings. The escalation ladder provides a clear view of issue severity and the corresponding supervisory response. For financial institutions, this means proactive, structured communication with supervisors can positively influence the escalation level and improve the SREP score. ADVISORI supports the development of SREP-optimised communication strategies.

How does the findings severity model (F1-F4) work in the SREP?

The new SREP findings severity model categorises supervisory findings into four severity levels: F1 (minor) and F2 (moderate) require only confirmation that remedial measures were taken — additional documentation is not required, but evidence must be retained for five years. F3 (serious) and F4 (critical) are subject to existing follow-up procedures with comprehensive documentation requirements and close monitoring. The correct classification determines resource allocation and the required response speed of the institution.

How does ADVISORI support implementing EBA-compliant escalation and communication structures?

ADVISORI supports financial institutions with a five-phase approach: (1) Analysis of existing communication and escalation processes against the new EBA/CP/2025/21 requirements. (2) Development of a tailored concept with clear escalation levels, communication matrix, and governance structure. (3) Implementation with defined responsibilities, KRI-based early warning systems, and digitalised reporting processes. (4) Training of executives and staff for handling the new structures. (5) Continuous evaluation and optimisation — including crisis scenario testing and audit readiness checks.