← Back to updates
ECB

ECB

Medium Impact

ECB publishes June 2026 Guide to internal models

Published

Jun 26, 2026

Topics

Internal models, IRB approach, Market risk internal models, Counterparty credit risk models, Model governance, Model validation, CRR, CRR3, SSM supervision

Executive Summary

The ECB’s June 2026 Guide to internal models should be treated as an updated supervisory reference point for significant institutions in the Single Supervisory Mechanism that use internal models, or that plan applications, extensions or model changes. The guide sits alongside binding CRR requirements and EBA technical standards and guidelines; it does not, on its own, create a new reporting template or a new statutory effective date. Business impact is therefore mainly on model risk management, supervisory-submission readiness, validation evidence, documentation standards and controls over model-change classification. Banks should compare the June 2026 guide with the prior ECB guide, update internal model application checklists and ensure planned submissions evidence compliance with CRR, CRR3-related changes and relevant EBA standards.

What Changed

modifiedUpdated ECB supervisory guide for internal models

Previous

Banks previously referenced earlier ECB Guide to internal models publications, including the February 2024 version.

New

Banks should use the June 2026 ECB Guide to internal models as the latest ECB supervisory guide when preparing internal model governance documentation, applications and model-change submissions.

modifiedSupervisory-submission evidence expectations

Previous

Internal model application and change packs were benchmarked against the prior ECB guide, CRR requirements and EBA standards.

New

Application and change packs should be benchmarked against the June 2026 guide, while continuing to comply with legally binding CRR provisions and EBA regulatory technical standards and guidelines.

modifiedCRR and CRR3 alignment context

Previous

Model frameworks were aligned to the existing CRR and earlier ECB/EBA supervisory expectations.

New

Banks should ensure internal model policies and capital-impact assessments reflect the current CRR text, including CRR3 amendments where applicable, as well as the June 2026 ECB guide.

newNo direct regulatory reporting-template amendment identified

New

No affected regulatory reporting template or field is identified from the source; impacted artefacts are internal model application packs, model-change assessments, validation reports and related governance workflows.

Business Impact

Who is affected

ECB-supervised significant institutions in participating SSM jurisdictions that use internal models for regulatory capital, or that plan to apply for internal model permissions, extensions or material model changes. Model risk management, regulatory capital, risk analytics, validation, internal audit, regulatory reporting and supervisory relations teams are likely stakeholders.

Jurisdictions

European Union, Banking Union / Single Supervisory Mechanism participating Member States, Euro area

Business processes

Internal model application preparation, Internal model extension and change assessment, Model-change materiality classification, Independent model validation, Model governance and committee approvals, Regulatory capital and RWA impact assessment, Supervisory engagement with ECB Joint Supervisory Teams and national competent authorities, Internal audit review of internal model controls

Estimated effort

Medium

Compliance risk

Medium

Affected Reports

Internal model permission applications and supporting evidence packsInternal model extension or change applications and notificationsModel-change materiality assessment filesIndependent model validation reportsModel governance committee approval packsCapital and RWA impact analyses supporting internal model changes
FieldValidation rule
Internal model application checklistAdd a control to evidence mapping to the June 2026 ECB Guide to internal models, applicable CRR provisions and relevant EBA technical standards or guidelines.
Model-change materiality assessmentDocument whether a planned internal model change is an extension, material change or non-material change under the applicable CRR and RTS framework before supervisory submission.
Independent validation evidenceEnsure validation reports contain sufficient evidence of methodology review, data assessment, performance testing, limitations, findings and remediation tracking before model approval or submission.
Governance approval recordRetain clear evidence of model owner, independent validation, senior management or committee approval, and escalation of material findings for internal model applications and changes.
Capital impact assessmentFor model changes, document the effect on own funds requirements and risk-weighted exposure amounts, including interaction with current CRR requirements and CRR3 amendments where applicable.

Recommended Actions

  1. 1

    Download and archive the June 2026 ECB Guide to internal models as a controlled regulatory reference document and record the publication date as June 2026.

  2. 2

    Perform a redline or thematic gap assessment against the prior ECB Guide to internal models and document changes affecting internal model governance, validation, methodology, data, use test and application evidence.

  3. 3

    Update internal model application and model-change submission templates so each evidence item is mapped to the June 2026 ECB guide, CRR requirements, CRR3 amendments and relevant EBA RTS or guidelines.

  4. 4

    Review the 2026–2027 internal model change pipeline and identify submissions that may need additional evidence, validation work or pre-submission engagement with the ECB Joint Supervisory Team or national competent authority.

  5. 5

    Refresh model-change materiality procedures to ensure extensions and changes are classified consistently with the applicable RTS framework before submission.

  6. 6

    Train model owners, validation teams, regulatory capital teams and internal audit on the updated guide and on how the guide affects supervisory evidence expectations.

  7. 7

    Confirm that no COREP, FINREP or other regulatory reporting template change is assumed solely from the guide; any reporting-template change should be tracked through separate EBA or ECB reporting-taxonomy publications.

Timeline

publication

May 20, 2014

Commission Delegated Regulation (EU) No 529/2014 on the materiality assessment of extensions and changes of internal approaches was published in the Official Journal.

publication

Mar 18, 2022

Commission Delegated Regulation (EU) 2022/439 on RTS for the IRB assessment methodology was published in the Official Journal.

publication

Feb 1, 2024

ECB prior version of the Guide to internal models was available as the February 2024 guide.

publication

Jun 19, 2024

Regulation (EU) 2024/1623 amending the CRR was published in the Official Journal.

effective date

Jan 1, 2025

Main application date for Regulation (EU) 2024/1623 amendments to the CRR, subject to exceptions in the regulation.

publication

Jun 1, 2026

ECB published the June 2026 Guide to internal models.

Sources

AI-generated analysis is based on the following primary sources. Always verify against the official publication.

Related Evidence

Similar official source documents found with semantic search.

Receive updates like this by email

Get AI-generated analysis for the regulators and topics you care about.