Regulatory Alerts2025-11-06
Royal Decree 999/2025 of 5 November amending Royal Decree 1012/2015 on the recovery and resolution of credit institutions and investment firms and modifying Royal Decree 2606/1996 on deposit guarantee schemes
The Spanish Ministry of Economy, Commerce and Enterprise issued Royal Decree 999/2025 to transpose EU Regulation 2022/2036, which amends the Bank Recovery and Resolution Directive regarding the prudential treatment of Global Systemically Important Institutions (G-SIIs) with multiple point of entry (MPE) resolution strategies. The decree modifies Articles 71.4 and 82.3 of Royal Decree 1012/2015 to require resolution authorities to include third-country entities that would qualify as resolution entities if established in the EU when calculating the Minimum Requirement for own funds and Eligible Liabilities (MREL). These adjustments ensure alignment with international Total Loss-Absorbing Capacity (TLAC) standards and minimize differences between MPE and single point of entry (SPE) resolution strategy requirements to promote equal treatment and financial stability.