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EstoniaFinantsinspektsioon

Estonia lists EBA criteria for identifying ancillary services undertakings

Banks should review activity classifications and the 50% principal-activity test. Finantsinspektsioon lists 10 August 2026; the EBA guidelines themselves apply from 4 May 2026.

By Taxxa AI OyPublished 10 August 2026

Financial Sector & Markets

Industry: Financial and insurance activities

Finantsinspektsioon lists 10 August 2026FI as the effective date for its publication of EBA/GL/2026/01 on identifying ancillary services undertakings.FI The underlying European Banking Authority guidelines state that they apply from 4 May 2026.FI Institutions assessing their prudential group structure should distinguish those dates when reviewing the criteria.

The guidelines explain which activities constitute a direct extension of banking or are ancillary to banking for the Capital Requirements Regulation definition. Direct extensions include specified activities in the core banking value chain, such as loan servicing, debt collection, creditworthiness assessment and collateral valuation. For those listed activities, the guidelines require that they be provided mainly to, or in the interests of, institutions or financial institutions.

The broader ancillary-activity test considers whether an activity supports or complements banking, or depends on it. The assessment must examine the relevant connection with banking activities. An abstract possibility of serving the same customer base is insufficient to establish that an activity complements banking: the guidelines call for an objective, factual assessment.

Examples cover operational support, risk management and compliance, property ownership or management, operating leases and data processing. The presence of one of those activities does not replace the applicable criteria. For example, the operating-lease discussion examines links to banking products, operational dependence and reliance on funding from institutions or financial institutions within the group.

The principal-activity test is also significant. The relevant activities, taken together, meet that test where they account for at least 50% of any one of the undertaking’s assets, revenues or staff, assessed on an individual basis.FI Even where none of those thresholds is reached, principal activity may still be established case by case to the competent authority’s satisfaction.

Institutions should document both the nature of an undertaking’s activities and the basis for treating those activities as its principal business. The guidelines also set exclusions, including undertakings already qualifying under specified financial-sector definitions for another reason. The legal framework is EBA/GL/2026/01FI, which specifies criteria under Article 4(1)(18) and Article 4(5) of Regulation (EU) No 575/2013.FI

Review ancillary-undertaking classifications and document the activities and principal-activity test.

Sources