Abstract

The EU has shaped the rules on bank crisis management on the paradigm of the large universal bank. Only limited consideration was given to small and traditional banks, which are placed under an artificial competitive disadvantage from a twofold perspective: ex post, for those few banks actually facing a crisis with an unsuitable toolbox; most importantly, ex ante, for all banks being required to meet complex and costly preparatory requirements, which are largely redundant. On 18 April 2023, the European Commission published a proposal for a directive that, in its stated intentions, aims to correct some of these issues, but seems to fall short of the objective