On 23 July 2025, the European Banking Authority (“EBA”) published its report on the scope of the interbank exemption (the “Interbank Exemption”) in Article 21c of CRD VI (the “EBA Report”).

In its report, the EBA considers whether the Interbank Exemption should be extended to other EU financial sector entities such as investment firms, asset management companies, payment service providers (“PSPs”) and insurers (each an “EU FSE”).

In summary, the EBA says there is insufficient evidence from market participants to justify expanding the scope of the Interbank Exemption to other EU FSEs. Whilst market participants may have been hoping for an expansion of this exemption to a wider set of entities, the EBA Report at least gives some certainty where banks were delaying elements of their programme pending publication of this report.

Firms will also need to consider the practical implications of the EBA Report, including on their existing CRD VI impact assessments and programme assumptions. Deloitte’s key observations from the report and potential practical implications are considered below.