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Report on Banks' Dry Run Testing of Recovery Plans

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Summary

The European Banking Authority published a Report analyzing how banks test their recovery plans through 'dry run' exercises. The analysis finds that most institutions recognize the value of dry runs and use lessons learned to improve arrangements, though approaches and maturity levels vary significantly. The Report is benchmarking in nature and not intended to provide prescriptive guidance.

What changed

The EBA published a Report comparing how banks test the implementation of their recovery plans through 'dry run' exercises. The analysis finds that most institutions recognize the value of dry runs and use lessons learned to improve their recovery planning arrangements. However, approaches and levels of maturity vary significantly across institutions. Where dry runs are carried out primarily to meet supervisory expectations, they tend to resemble compliance exercises with limited insights. Institutions with more advanced practices fully embed recovery planning within their broader risk management framework.

For banks and financial institutions, the Report provides useful benchmarks for assessing and improving dry run practices without imposing prescriptive requirements. The EBA highlights that regular, high-quality testing of key recovery plan elements enhances crisis readiness and institutional response capability. The Report also notes potential benefits from stronger synergies between recovery and resolution testing activities.

What to do next

  1. Monitor EBA benchmarks for recovery plan dry run testing practices
  2. Review internal dry run exercises against EBA findings to assess maturity level
  3. Consider integrating recovery and resolution testing activities

Archived snapshot

Apr 14, 2026

GovPing captured this document from the original source. If the source has since changed or been removed, this is the text as it existed at that time.

The EBA publishes Report on banks’ dry run testing of their recovery plans

  • Press Release
  • 13 April 2026

The European Banking Authority (EBA) today published a Report comparing how banks test the implementation of their recovery plans through so-called “dry runs”. In a context of heightened uncertainty and the continued need for operational preparedness and resilience to unexpected stress events, the analysis confirms that dry runs are an effective tool to strengthen the operationalisation of recovery plans and enhance institutions’ crisis readiness. When used meaningfully, dry runs improve institutions’ ability to respond to stress situations in a timely and credible manner.

The analysis finds that most institutions recognise the value of dry runs and use the lessons learned to improve their recovery planning arrangements. However, approaches and levels of maturity vary significantly across institutions.

Where dry runs are carried out primarily to meet supervisory expectations, they tend to be less effective, resembling compliance exercises with limited insights and follow-up actions. By contrast, institutions with more advanced practices use dry runs as genuine management tools, fully embedding recovery planning within their broader risk management framework. In these cases, dry runs strengthen internal preparedness by enhancing the credibility, feasibility and organisational understanding of recovery planning arrangements.

Looking ahead, the EBA highlights the importance for institutions to maintain regular, high-quality testing of key recovery plan elements and to continue refining  their dry run practices. The Report also points to the potential benefits of stronger synergies and better integration of testing activities across the recovery and resolution, supporting a more effective crisis management continuum.

Legal basis and next steps

In line with the EBA supervisory convergence priorities, under which the usability and testing of recovery plans is a key focus for prudential supervisors in 2026, the EBA has conducted a thematic comparative analysis on recovery plan dry runs. The work also reflects the EBA’s broader mandate to contribute to effective recovery and resolution planning.

The Report is particularly timely in light of recent and upcoming developments, including:

  • the publication of the EBA Handbook on Simulation Exercises for Resolution Authorities, which sets out methodologies and good practices for coordinated simulation exercises;
  • the EBA’s preparation its future mandate under the Crisis Management and Deposit Insurance (CMDI) regulatory framework to coordinate EU-wide simulation exercises across competent and resolution authorities. This benchmarking exercise is not intended to provide prescriptive guidance. Rather, it aims to support institutions in the further development of their dry run practices and to contribute to the establishment of useful benchmarks for their implementation.

Documents

Report on recovery plans dry runs

(1.04 MB - PDF)

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Franca Rosa Congiu

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Last updated

Classification

Agency
EBA
Published
April 13th, 2026
Instrument
Notice
Legal weight
Non-binding
Stage
Final
Change scope
Minor

Who this affects

Applies to
Banks Insurers
Industry sector
5221 Commercial Banking
Activity scope
Recovery plan testing Crisis preparedness Dry run exercises
Geographic scope
European Union EU

Taxonomy

Primary area
Banking
Operational domain
Risk Management
Compliance frameworks
Basel III
Topics
Financial Services

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