Recital 13
(13) In order to duly assess potential unintended consequences of the indirect subscription of internal MREL eligible resources, including the new deduction regime, and to ensure a proportionate treatment and level playing field between different types of banking group structures, especially institutions that have an operating company between the holding company and its subsidiaries, and for entities whose resolution plan provides for their winding up under normal insolvency proceedings in the case of failure, the Commission should review the implementation of the indirect subscription of internal MREL eligible resources by the different types of banking group structures as soon as possible. The Commission should duly assess possible structural solutions to any identified issues such as enlarging the possibility for entities that are not themselves resolution entities to comply with their MREL on a consolidated basis. The accompanying legislative proposal that the Commission may adopt should duly consider the date of application of the dedicated treatment for the indirect subscription of internal MREL eligible resources, so that it can be implemented before Article 72e(5) of Regulation (EU) No 575/2013 becomes applicable. Such a legislative proposal should preferably be a dedicated one.
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Source: EUR-Lex (Cellar) · retrieved 2026-10-16 · Text as adopted (Official Journal); later amendments are not incorporated in this text.