Greece: Financial Sector Assessment Program-Technical Note on Regulation and Supervision of Less Significant Institutions

IMF Staff Country Reports, June 17, 2026

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Canonical URL: Greece: Financial Sector Assessment Program-Technical Note on Regulation and Supervision of Less Significant Institutions

Supervision of less significant institutions (LSIs) is effective in Greece.
The Bank of Greece (BoG) approach to LSI supervision is described as thorough, systematic and intrusive.
The core of the supervisory approach is the Supervisory Review and Evaluation Process (SREP), an EU framework that BoG uses with adaptations for Greece, its local risks and environment.
The SREP process is transparent internally and to the LSIs themselves, with risks clearly identified and reflected in both supervisory actions and Pillar 2 capital add-ons.
BoG benefits from robust independence and an ability to attract and retain staff with the desired skills and experience, as illustrated during the last recruitment process.
BoG has increased resources to reflect changing needs (such as DORA implementation).
Collaboration and coordination with other parties are effective, both internally (such as the AML supervisors) and externally (with other supervisors and authorities).
One area identified for improvement is the enforcement and sanctioning regime, where penalties might better reflect the offence and provide the right level of deterrence.

Emerging risks requiring continued vigilance:
- Information Communication Technologies (ICT)
- Cyber
Resourcing observations:
- Increased resources have been allocated for changing needs (example cited: DORA implementation).
- A need exists for some medium-term resource planning to ensure emerging risks are adequately resourced.

SREP implementation:
- BoG uses the EU SREP framework with Greek-specific adaptations.
- The process is systematic, intrusive, and transparent to both supervisors and supervised entities.
- Identified risks are translated into supervisory actions and Pillar 2 capital add-ons.
Coordination:
- Effective collaboration internally (including AML supervisors).
- Effective external coordination with other supervisors and authorities.

BoG governance attributes:
- Robust independence enabling effective supervision.
- Demonstrated ability to attract and retain skilled staff (evidence: last recruitment process).
Staffing and capacity:
- Increased staffing/resources to address new requirements.
- Recommendation for medium-term planning to match staffing with evolving risks.

Identified shortcoming:
- Enforcement and sanctioning regime could be tighter and better calibrated.
- Penalties may not always reflect the offence or provide the appropriate level of deterrence.