Circular Letter No. CC/2026/00000022: Applicability of EBA Guidelines on the concept of 'connected clients' to less significant credit institutions

Circular Letter No. CC/2026/00000022 Mod. 99999924/T – 01/14 Subject: Applicability of the EBA Guidelines on the concept of 'connected clients' established in point 39 of paragraph 1 of Article 4 of Regulation (EU) No. 575/2013 (CRR) (EBA/GL/2017/15) to less significant credit institutions and entities identified in Article 1 of Notice No. 11/2014

The European Banking Authority (EBA) published, on February 23, 2018, the Guidelines on the concept of connected clients, established in point 39 of paragraph 1 of Article 4 of Regulation (EU) No. 575/2013 of the European Parliament and of the Council of June 26, 2013, on prudential requirements for credit institutions ('CRR'), designated as 'EBA Guidelines EBA/GL/2017/15'.

These Guidelines, published on February 23, 2018, clarify, within the framework of the large exposures regime under the CRR, the requirements for control, economic interdependence, and the relationship between them, to assess the existence of clients or groups of connected clients that constitute a single entity from a risk perspective.

In the context of the implementation of these Guidelines by the Bank of Portugal, less significant credit institutions were bound to comply with them under Instruction No. 28/2018.

Regarding entities covered by Article 1 of Notice No. 11/2014, which carry out activities and incur risks similar to those of credit institutions, the Bank of Portugal issued Circular Letter No. CC/2023/00000017, recommending the application of EBA Guidelines EBA/GL/2017/15 to those entities.

With the publication of Delegated Regulation (EU) 2024/1728 of the Commission of December 6, 2023, which complements the CRR with regard to regulatory technical standards specifying the circumstances in which the conditions for identifying groups of connected clients are met, a significant part of the content of EBA Guidelines EBA/GL/2017/15 was replaced by the Delegated Regulation, applicable to credit institutions from July 8, 2024, with the exception of Sections 5 and 8 of the Guidelines, which remain applicable. Sections 5 and 8 of EBA Guidelines EBA/GL/2017/15 refer, respectively, to the 'Alternative approach for risks incurred on central administrations' and 'Control and management procedures to identify connected clients'.

On April 29, 2026, the EBA published Decision EBA/DC/644, relating to the partial elimination of Sections 4, 6, and 7 of the Guidelines.

The Bank of Portugal emphasizes the importance of less significant credit institutions and entities identified in Article 1 of Notice No. 11/2014 giving due compliance to Sections 5 and 8 of EBA Guidelines EBA/GL/2017/15, without prejudice to the direct applicability in national law of Delegated Regulation (EU) 2024/1728 of the Commission of December 6, 2023. Sections 5 and 8 of the Guidelines must be followed and applied in the context of the legislation and regulation in force applicable to them. These will be taken into consideration by the Bank of Portugal in the interpretation of the legal and regulatory provisions applicable to institutions, for the purpose of verifying compliance therewith.

Mod. 99999924/T – 01/14 This Circular Letter replaces Circular Letter No. CC/2023/00000017.

EBA Guidelines EBA/GL/2017/15: https://www.eba.europa.eu/activities/single-rulebook/regulatory-activities/large-exposures/guidelines-connected-clients https://www.eba.europa.eu/sites/default/files/documents/10180/2135623/4ee3a765-387e-447c-b6a4-5a8a34b0792e/Guidelines%20on%20connected%20clients%20(EBA-GL-2017-15)_PT.pdf?retry=1