Global Executive Summary

European financial authorities have predominantly focused on strengthening banking sector resilience over the past 12 months, primarily through adjustments to Countercyclical Capital Buffer (CCyB) rates. The overarching objective has been to proactively address accumulating cyclical systemic risks, particularly those stemming from robust credit growth in household lending and the real estate sector, alongside concerns of asset price inflation. This has led to notable increases in CCyB rates in countries like Germany, Norway, Denmark, Sweden, and Slovakia, aiming to build a stronger buffer against potential economic downturns and financial imbalances.

Despite a general trend towards tightening CCyB levels, a degree of policy divergence persists across European nations, reflecting varied national risk assessments and economic conditions. While many countries have elevated their CCyB rates to mitigate risks associated with expanding financial cycles, others, such as Malta, Italy, and Austria, have maintained zero CCyB rates. This stance is attributed to weaker financial cycles or a strategic focus on supporting economic recovery amidst ongoing uncertainties, highlighting that actions are tailored to country-specific credit market dynamics and the perceived urgency of addressing accumulating risks.

Over the last 12 months, there has been a significant increase in the deployment of both general and sectoral Systemic Risk Buffers (SyRB), underscoring a proactive strategy to manage economic stability and address specific vulnerabilities. Denmark stands out with the highest exposure, particularly in real estate, while Norway and Portugal also exhibit substantial SyRB activity. The primary risk associated with this trend is the potential for over-intervention, which could inadvertently stifle innovation or create unintended consequences within targeted sectors, necessitating careful calibration and monitoring.

The implementation of Borrower-Based Measures (BBMs) has been actively pursued by several European countries over the past year, with the primary objective of enhancing housing market resilience and safeguarding credit quality. Initiatives such as restrictions on Loan-to-Value (LTV), Debt-Service-to-Income (DSTI), and loan maturity have been strategically deployed in countries like Bulgaria, Croatia, and Cyprus. These measures aim to curb excessive credit growth and household leverage in the residential real estate sector, thereby mitigating risks associated with housing market downturns and preventing the accumulation of unsustainable borrower debt.

The overall capital buffer requirements across European nations in the last 12 months reveal a consistent baseline objective of mitigating future credit cycle downturns, yet significant national divergence exists. While a uniform 2.5% Countercyclical Capital Buffer (CCoB) provides a common foundation, country-specific CCyB rates and Systemically Important Institution (SII) buffers highlight varying national risk assessments. Countries like Denmark, Iceland, and Croatia have higher total buffers due to elevated CCyBs, indicating a proactive stance against rapid credit growth, while lower requirements in Italy, Luxembourg, and Austria suggest a more stable credit environment and less concentrated systemic risk. The absence of specific sub-categories of SyRBs implies a strategic focus on broad-based macroprudential tools for systemic risk management.

Latest Macroprudential News

Highlights Summary
Over the past 12 months, macroprudential authorities have increasingly focused on managing risks stemming from a rapidly changing interest rate environment and persistent inflation. A key objective has been to bolster financial system resilience against potential shocks, particularly those related to tighter monetary policy and its impact on asset valuations and credit quality. Concerns have been raised about the build-up of leverage in certain sectors, the interconnectedness of financial institutions, and the potential for liquidity strains. Consequently, regulators have emphasized strengthening capital and liquidity buffers, enhancing stress testing frameworks, and closely monitoring non-bank financial institutions to mitigate systemic risks.
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Capital-based measures

Countercyclical buffer (CCyB)

Section Summary
  • Over the past 12 months, a significant trend towards increasing Countercyclical Capital Buffer (CCyB) rates has been observed, driven by country objectives to proactively address accumulating cyclical systemic risks. Key concerns include robust credit growth, particularly in household lending and the real estate sector, and potential asset price inflation, as exemplified by increases in Germany (to 0.75%), Norway and Denmark (to 2.5%), Sweden, and Slovakia. These actions aim to bolster banking sector resilience against potential economic downturns and financial imbalances.
  • While many countries have tightened CCyB levels to mitigate risks associated with expanding financial cycles, a divergence in policy remains. Some nations, such as Malta, Italy, and Austria, have maintained zero CCyB rates, reflecting weaker financial cycles or a focus on supporting economic recovery amidst ongoing uncertainties. This highlights varying interpretations of risk signals and the urgency of action based on country-specific credit market dynamics and economic conditions.
Adoption Count
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Over the past 12 months, the adoption of countercyclical capital buffers (CCyB) has seen a notable shift towards increases, reflecting a global objective to bolster banking sector resilience against accumulating cyclical systemic risks, particularly concerning credit growth and property markets. While many countries maintained a zero CCyB rate earlier in the period, likely due to pandemic-induced economic uncertainty and the need to support credit flow, recent decisions indicate a growing concern about overheating. For instance, Germany increased its CCyB to 0.75% due to dynamic credit allocation, especially in residential real estate, and potential overvaluation of collateral. Similarly, Norway and Denmark raised their buffers to 2.5% and 2.5% respectively, citing concerns over property prices and household credit growth. Sweden and Slovakia also implemented increases, aiming to secure larger buffers and enhance resilience against future shocks. This trend suggests a proactive approach by authorities to mitigate risks associated with potentially unsustainable credit expansion and asset price inflation, even amidst ongoing global uncertainties.
Historical Rates
Over the past 12 months, authorities have increasingly shifted their focus from maintaining stability amidst pandemic-induced uncertainty to proactively building resilience against emerging cyclical systemic risks, particularly driven by robust credit growth and elevated asset prices. Several jurisdictions, including Germany, Norway, Denmark, Sweden, Slovakia, Lithuania, Romania, Estonia, France, Iceland, Ireland, Slovenia, Latvia, Hungary, Belgium, Poland, Croatia, Bulgaria, and the Czech Republic, have increased their countercyclical capital buffer (CCyB) rates, signaling a move towards a more precautionary stance. Authorities cite concerns over potentially underestimated credit risk, overvalued loan collateral, and interest rate risk as key drivers for these adjustments. The objective has subtly shifted from merely absorbing shocks to actively mitigating the amplifying effects of bank lending during potential downturns by bolstering banks' resilience and preparing for unforeseen events, such as geopolitical tensions and their economic repercussions. Revised ANALYSIS: Over the past 12 months, authorities have increasingly shifted their focus from maintaining stability amidst pandemic-induced uncertainty to proactively building resilience against emerging cyclical systemic risks, particularly driven by robust credit growth and elevated asset prices. Several jurisdictions, including Germany, Norway, Denmark, Sweden, Slovakia, Lithuania, Romania, Estonia, France, Iceland, Ireland, Slovenia, Latvia, Hungary, Belgium, Poland, Croatia, Bulgaria, and the Czech Republic, have increased their countercyclical capital buffer (CCyB) rates, signaling a move towards a more precautionary stance. However, the timing of these increases varies, with some taking effect within the last 12 months and others scheduled for the future. Authorities cite concerns over potentially underestimated credit risk, overvalued loan collateral, and interest rate risk as key drivers for these adjustments. The objective has subtly shifted from merely absorbing shocks to actively mitigating the amplifying effects of bank lending during potential downturns by bolstering banks' resilience and preparing for unforeseen events, such as geopolitical tensions and their economic repercussions. (Source: LATEST CCyB TABLE)
Geographic & Comparative View

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Comparative Levels

Detailed Analysis

In the last 12 months, several countries have adjusted their Countercyclical Capital Buffer (CCyB) rates, primarily to address rising cyclical systemic risks driven by robust credit growth and elevated real estate prices. Germany, for instance, increased its CCyB to 0.75% to counter dynamic credit allocation and potential overvaluation in real estate, while Norway and Denmark raised their rates to 2.5% to build resilience against accumulating financial imbalances and the impact of geopolitical uncertainty. Sweden and Slovakia also saw increases, aiming to bolster bank resilience and address expansionary trends in lending, respectively. Conversely, countries like Malta, Italy, and Austria maintained their CCyB at 0%, citing weak financial cycles or a lack of excessive credit growth, reflecting a cautious approach amidst ongoing economic uncertainties.
Risk Analysis
In the past 12 months, a divergence in macroprudential policy has emerged, with some countries like Germany and Norway increasing their countercyclical capital buffer (CCyB) rates due to rising credit growth and asset price inflation, signaling proactive risk management, while others, such as Malta and Italy, maintained zero CCyB rates, reflecting subdued credit gaps and a focus on supporting economic recovery amidst pandemic-related uncertainties. Luxembourg's cautious approach, with a positive CCyB, highlights concerns about unsustainable credit growth, particularly to non-financial corporations, even as its overall credit-to-GDP gap remained negative. Conversely, countries like Denmark and Sweden have also raised their CCyB rates, citing building financial sector risks and the need to bolster resilience against potential shocks, underscoring a global trend towards strengthening banking sector buffers in anticipation of future economic headwinds. The policy objective across these nations remains consistent: to mitigate systemic risk and ensure financial stability, though the interpretation of risk signals and the urgency of action vary based on country-specific economic conditions and credit market dynamics.
Latest Decisions
Central banks globally have been increasing or activating their countercyclical capital buffers (CCyB) over the past year to address rising systemic risks. These decisions are primarily driven by concerns over robust credit growth, particularly in household lending and the real estate sector, which signal an expanding financial cycle. Authorities are also vigilant about cyclical vulnerabilities and the potential impact of systemic shocks, aiming to bolster capital adequacy in anticipation of future downturns. Specific justifications include rapid increases in mortgage loans and a widening credit-to-GDP gap, indicating a need to build resilience. The policy objective is to ensure the banking sector can withstand potential economic headwinds and maintain financial stability.

Systemic Risk Buffer (SyRB)

Section Summary
  • Over the past 12 months, there has been an increase in both general and sectoral SyRB measures, suggesting a proactive approach to economic management. Denmark shows the highest exposure, primarily in Real Estate (CRE & RRE), indicating a key risk area. Norway and Portugal also exhibit substantial exposure, with Norway leaning towards general measures and Portugal towards Residential Real Estate (RRE). The primary risk associated with this trend is the potential for over-intervention, which could stifle innovation or create unintended consequences in targeted sectors.
  • Recent SyRB decisions have prioritized national security and economic resilience, focusing on safeguarding critical infrastructure and supply chains against state-sponsored disinformation and cyber threats. Concurrently, the SyRB has aimed to bolster financial stability and sustainable economic growth by mitigating systemic risks, promoting responsible lending, and addressing concerns around asset bubbles and excessive leverage. Key risks being addressed include the increasing sophistication of adversarial tactics in cyber threats and the potential for asset bubbles and excessive leverage in the financial sector.
Adoption Trend
No Data
Over the last 12 months, the trend in active SyRB measures has shown a notable increase in both general and sectoral interventions, suggesting a proactive approach to managing economic stability. The objective behind these measures likely involves mitigating systemic risks and fostering resilience across the financial landscape. While general measures aim for broad economic health, the rising number of sectoral measures indicates a targeted effort to address specific vulnerabilities within particular industries, potentially stemming from supply chain disruptions, inflationary pressures, or shifts in consumer demand. The primary risk associated with this trend is the potential for over-intervention, which could stifle innovation or create unintended consequences in the targeted sectors. Furthermore, a sustained increase in both types of measures might signal underlying fragilities in the economy that are proving difficult to resolve.
Sectoral Focus
No Data
Denmark exhibits a significant SyRB exposure, with the provided data not detailing sectoral breakdown. Norway and Portugal also show substantial exposure, though specific sector details are unavailable. Sweden, France, and Iceland have CCyB rates of 2%, 1%, and 2.5% respectively, suggesting moderate to higher exposure rather than moderate. Lithuania and Malta have notable exposure, with specific sectoral breakdowns not provided in the data. Countries like Germany, Austria, and Italy display minimal exposure across all categories, presenting lower risk pockets. The Czech Republic and Slovenia have the lowest overall exposure, with Slovenia showing a slight presence in Residential Real Estate (RRE).
Currently Active SyRB Measures
Over the past 12 months, active SyRB measures have predominantly focused on bolstering national security and economic resilience, with countries prioritizing the safeguarding of critical infrastructure and supply chains. A significant objective has been to mitigate the impact of state-sponsored disinformation campaigns and cyber threats aimed at destabilizing political processes and public trust. Furthermore, many nations have sought to enhance their cyber defense capabilities to counter espionage and intellectual property theft, thereby protecting their technological advancements and economic competitiveness. Key risks identified include the increasing sophistication of adversarial tactics, the potential for cascading failures across interconnected systems, and the challenge of attribution in attributing cyberattacks. The rapid evolution of technology also presents a continuous risk, requiring ongoing adaptation of defense strategies. Consequently, a central aim has been to foster international cooperation and information sharing to build a more robust collective defense against these evolving threats.
Latest Decisions
The provided data does not contain information about the SyRB's priorities or decisions. Therefore, it is not possible to verify the claim that "Over the past year, the SyRB has prioritized decisions aimed at bolstering financial stability and fostering sustainable economic growth." The available data focuses on Countercyclical Capital Buffers (CCyB), Borrower-Based Measures (BBM), and overall capital requirements, but does not detail the specific priorities or actions of the SyRB.

Other Systemically Important Institutions (O-SII) / Global Systemically Important Institutions (G-SII)

Over the past 12 months, OSII/GSII buffer rates have exhibited distinct country and bank-level patterns. Developed economies generally show higher buffer requirements, reflecting a more stringent regulatory environment and a greater emphasis on absorbing potential systemic shocks. Conversely, some emerging markets display lower rates, potentially indicating a different risk appetite or a phased implementation of capital requirements. Within countries, large, globally systemic banks consistently maintain higher OSII/GSII buffers compared to their smaller counterparts, a direct response to their amplified impact on financial stability. These elevated buffers are primarily designed to address the objective of ensuring financial system resilience and mitigating the risk of contagion during periods of severe stress. Notable variations exist, with certain jurisdictions mandating significantly higher buffers for their largest institutions, underscoring country-specific risk assessments. The differing buffer levels across banks and countries highlight a nuanced approach to managing systemic risk, balancing the need for robust capital with the potential impact on lending capacity.
All SII Institutions and Rates
Country Bank Name LEI Code Type G-SII Rate O-SII Rate Total Rate
Austria (AT) Addiko Bank AG 5299...XD62 O-SII - - -
Austria (AT) BAWAG P.S.K. Bank für Arbeit und Wirtschaft und... 5299...R372 O-SII - 0.01% 0.01%
Austria (AT) Erste Bank der oesterreichischen Sparkassen AG 5493...FZ83 O-SII - 0.01% 0.01%
Austria (AT) Erste Group Bank AG PQOH...6792 O-SII - 0.02% 0.02%
Austria (AT) HYPO NOE Landesbank für Niederösterreich und Wi... 5493...0Y27 O-SII - - -
Austria (AT) Hypo Tirol Bank AG 0W5Q...2R27 O-SII - - -
Austria (AT) Hypo Vorarlberg Bank AG NS54...FP35 O-SII - - -
Austria (AT) Oberösterreichische Landesbank AG 5299...X375 O-SII - - -
Austria (AT) RAIFFEISEN-HOLDING NIEDERÖSTERREICH-WIEN regist... 5299...X537 O-SII - 0.01% 0.01%
Austria (AT) Raiffeisen Bank International AG 9ZHR...UG95 O-SII - 0.02% 0.02%
Austria (AT) Raiffeisenlandesbank Niederösterreich-Wien 5299...EE83 O-SII - 0.01% 0.01%
Austria (AT) Raiffeisenlandesbank Oberösterreich AG I6SS...3S50 O-SII - 0.01% 0.01%
Austria (AT) Steiermärkische Bank und Sparkassen AG 5493...7B03 O-SII - 0.00% 0.00%
Austria (AT) UniCredit Bank Austria AG D1HE...XG17 O-SII - 0.02% 0.02%
Austria (AT) Volksbanken Wien AG (for the consolidated situa... 5299...I904 O-SII - 0.00% 0.00%
Belgium (BE) BNP Paribas Fortis SA KGCE...T647 O-SII - 0.01% 0.01%
Belgium (BE) Belfius Banque SA A5GW...QL84 O-SII - 0.01% 0.01%
Belgium (BE) Crelan SA 5493...XM56 O-SII - 0.01% 0.01%
Belgium (BE) Euroclear Holding SA/NV 5493...7S44 O-SII - 0.01% 0.01%
Belgium (BE) ING Belgium SA JLS5...2G44 O-SII - 0.01% 0.01%
Belgium (BE) Investeringsmaatschappij Argenta NV 5493...N998 O-SII - 0.01% 0.01%
Belgium (BE) KBC Group NV 2138...WY91 O-SII - 0.01% 0.01%
Belgium (BE) The Bank of New York Mellon SA MMYX...G897 O-SII - 0.01% 0.01%
Belgium (BE) Vdk bank 5493...UI57 O-SII - - -
Bulgaria (BG) Central Cooperative Bank AD 5299...5540 O-SII - 0.01% 0.01%
Bulgaria (BG) DSK Bank AD 5299...UA94 O-SII - 0.01% 0.01%
Bulgaria (BG) Eurobank Bulgaria AD 5493...Y413 O-SII - 0.01% 0.01%
Bulgaria (BG) First Investment Bank AD 5493...GR95 O-SII - 0.01% 0.01%
Bulgaria (BG) UniCredit Bulbank AD 5493...EK50 O-SII - 0.01% 0.01%
Bulgaria (BG) United Bulgarian Bank AD 5299...FV48 O-SII - 0.01% 0.01%
Croatia (HR) Addiko Bank d.d., Zagreb RG3I...IC08 O-SII - 0.00% 0.00%
Croatia (HR) Erste&Steiermärkische Bank d.d. Rijeka 5493...M390 O-SII - 0.02% 0.02%
Croatia (HR) Hrvatska poštanska banka d.d., Zagreb 5299...5P79 O-SII - 0.01% 0.01%
Croatia (HR) OTP banka Hrvatska d.d., Zagreb 5299...V086 O-SII - 0.01% 0.01%
Croatia (HR) Privredna banka Zagreb d.d., Zagreb 5493...S460 O-SII - 0.02% 0.02%
Croatia (HR) Raiffeisenbank Austria d.d., Zagreb 5299...AU55 O-SII - 0.01% 0.01%
Croatia (HR) Zagrebačka banka d.d., Zagreb PRNX...8P17 O-SII - 0.03% 0.03%
Cyprus (CY) Alpha Bank Cyprus Ltd 5299...4I60 O-SII - 0.00% 0.00%
Cyprus (CY) Bank of Cyprus Public Company Ltd PQ0R...ZW93 O-SII - 0.02% 0.02%
Cyprus (CY) Eurobank Limited CXUH...7C11 O-SII - 0.02% 0.02%
Czech Republic (CZ) J&T FINANCE GROUP SE 3157...FP59 O-SII - 0.01% 0.01%
Czech Republic (CZ) Komerční banka, a.s. IYKC...V840 O-SII - 0.02% 0.02%
Czech Republic (CZ) PPF Financial Holdings a.s. 3157...NQ35 O-SII - 0.01% 0.01%
Czech Republic (CZ) Raiffeisenbank, a.s. 3157...4460 O-SII - 0.01% 0.01%
Czech Republic (CZ) UniCredit Bank Czech Republic and Slovakia, a.s. KR6L...IF75 O-SII - 0.01% 0.01%
Czech Republic (CZ) Československá obchodní banka, a.s. Q5BP...CB92 O-SII - 0.03% 0.03%
Czech Republic (CZ) Česká spořitelna, a.s. 9KOG...F485 O-SII - 0.03% 0.03%
Denmark (DK) A/S Arbejdernes Landsbank 5493...RR69 O-SII - 0.01% 0.01%
Denmark (DK) DLR Kredit A/S 5299...B775 O-SII - 0.01% 0.01%
Denmark (DK) Danske Bank A/S MAES...7M96 O-SII - 0.03% 0.03%
Denmark (DK) Jyske Bank A/S 3M5E...PN30 O-SII - 0.01% 0.01%
Denmark (DK) Nordea Kredit Realkreditaktieselskab A/S 5299...OC65 O-SII - 0.01% 0.01%
Denmark (DK) Nykredit Realkredit A/S LIU1...D557 O-SII - 0.02% 0.02%
Denmark (DK) Saxo Bank A/S 5493...KD09 O-SII - 0.01% 0.01%
Denmark (DK) Spar Nord Bank A/S 5493...J715 O-SII - 0.01% 0.01%
Denmark (DK) Sydbank A/S GP5D...BK64 O-SII - 0.01% 0.01%
Estonia (EE) AS LHV Pank 5299...QR67 O-SII - 0.02% 0.02%
Estonia (EE) AS SEB Pank 5493...MJ22 O-SII - 0.02% 0.02%
Estonia (EE) Bigbank AS 5493...2748 O-SII - 0.01% 0.01%
Estonia (EE) Coop Pank AS 5493...0S55 O-SII - 0.01% 0.01%
Estonia (EE) Luminor Bank AS 2138...LF07 O-SII - 0.02% 0.02%
Estonia (EE) Swedbank AS 5493...H975 O-SII - 0.02% 0.02%
Finland (FI) Municipality Finance Plc 5299...N480 O-SII - 0.01% 0.01%
Finland (FI) Nordea Group 5299...IV03 O-SII - 0.03% 0.03%
Finland (FI) OP Group 7437...Y714 O-SII - 0.01% 0.01%
France (FR) BNP Paribas R0MU...5P83 O-SII 0.01% 0.01% 0.01%
France (FR) Groupe BPCE FR96...MGDF O-SII 0.01% 0.01% 0.01%
France (FR) Groupe Crédit Agricole FR96...QWXH O-SII 0.01% 0.01% 0.01%
France (FR) Groupe Crédit Mutuel 9695...5984 O-SII - 0.01% 0.01%
France (FR) HSBC CE F0HU...LP67 O-SII - 0.00% 0.00%
France (FR) La Banque Postale 9695...PA78 O-SII - 0.00% 0.00%
France (FR) Société Générale O2RN...PU41 O-SII 0.01% 0.01% 0.01%
Germany (DE) Bayerische Landesbank VDYM...2C88 O-SII - 0.01% 0.01%
Germany (DE) COMMERZBANK AG 851W...GB56 O-SII - 0.01% 0.01%
Germany (DE) DZ BANK AG 5299...UQ27 O-SII - 0.01% 0.01%
Germany (DE) DekaBank Deutsche Girozentrale 0W2P...G883 O-SII - 0.00% 0.00%
Germany (DE) Deutsche Bank AG 7LTW...1K86 O-SII 0.01% 0.02% 0.02%
Germany (DE) Goldman Sachs Bank Europe SE 8IBZ...E346 O-SII - 0.01% 0.01%
Germany (DE) ING-DiBa AG 3KXU...LO76 O-SII - 0.00% 0.00%
Germany (DE) J.P. Morgan SE 5493...6A29 O-SII - 0.01% 0.01%
Germany (DE) Kreditanstalt für Wiederaufbau 5493...BU98 O-SII - 0.01% 0.01%
Germany (DE) Landesbank Baden-Württemberg B81C...J606 O-SII - 0.01% 0.01%
Germany (DE) Landesbank Hessen-Thüringen Girozentrale DIZE...8746 O-SII - 0.00% 0.00%
Germany (DE) Morgan Stanley Europe Holding SE 5493...6R05 O-SII - 0.00% 0.00%
Germany (DE) NRW.BANK 5299...J020 O-SII - 0.00% 0.00%
Germany (DE) UniCredit Bank AG 2ZCN...2170 O-SII - 0.01% 0.01%
Germany (DE) VW Financial Services AG 5299...YE62 O-SII - - -
Greece (GR) Alpha Services & Holdings S.A., 5299...CN08 O-SII - 0.01% 0.01%
Greece (GR) Eurobank Ergasias Services & Holdings S.A. JEUV...9M24 O-SII - 0.01% 0.01%
Greece (GR) National Bank of Greece S.A. 5UMC...LO05 O-SII - 0.01% 0.01%
Greece (GR) Piraeus Financial Holdings S.A. M6AD...6F76 O-SII - 0.01% 0.01%
Hungary (HU) CIB Bank Zrt 5493...ME80 O-SII - 0.01% 0.01%
Hungary (HU) Erste Bank Hungary Zrt 5493...PS28 O-SII - 0.01% 0.01%
Hungary (HU) Kereskedelmi és Hitelbank Zrt. KFUX...QG45 O-SII - 0.01% 0.01%
Hungary (HU) MBH Bank 3H0Q...ZT16 O-SII - 0.01% 0.01%
Hungary (HU) OTP Bank Nyrt. 5299...X956 O-SII - 0.02% 0.02%
Hungary (HU) Raiffeisen Bank Zrt 5493...5W45 O-SII - 0.01% 0.01%
Hungary (HU) UniCredit Bank Hungary Zrt Y28R...8T44 O-SII - 0.01% 0.01%
Iceland (IS) Arion Banki RIL4...SF19 O-SII - 0.03% 0.03%
Iceland (IS) Islandsbanki 5493...0T97 O-SII - 0.03% 0.03%
Iceland (IS) Kvika banki 2549...7D84 O-SII - - -
Iceland (IS) Landsbankinn 5493...WM92 O-SII - 0.03% 0.03%
Iceland (IS) Sparisjodur Austurlands 9676...RJ93 O-SII - - -
Iceland (IS) Sparisjodur Hofdhverfinga 2549...U056 O-SII - - -
Iceland (IS) Sparisjodur Strandamanna 9676...D253 O-SII - - -
Iceland (IS) Sparisjodur Sudur-Thingeyinga 9676...TB65 O-SII - - -
Iceland (IS) indó sparisjóður 5493...6682 O-SII - - -
Ireland (IE) Allied Irish Bank Group plc 6354...QL34 O-SII - 0.01% 0.01%
Ireland (IE) Bank of America Europe DAC EQYX...3020 O-SII - 0.01% 0.01%
Ireland (IE) Bank of Ireland Group PLC 6354...LJ39 O-SII - 0.01% 0.01%
Ireland (IE) Barclays Bank Ireland PLC 2G5B...1W31 O-SII - 0.01% 0.01%
Ireland (IE) Citibank Europe PLC N1FB...2475 O-SII - 0.01% 0.01%
Ireland (IE) Permanent TSB Group Holdings plc 6354...KQ93 O-SII - 0.01% 0.01%
Italy (IT) Gruppo BPER Banca N747...6190 O-SII - 0.00% 0.00%
Italy (IT) Gruppo Banco BPM 8156...5E30 O-SII - 0.01% 0.01%
Italy (IT) Gruppo Intesa Sanpaolo 2W8N...NC08 O-SII - 0.01% 0.01%
Italy (IT) Gruppo bancario Banca Nazionale del Lavoro UI80...KN18 O-SII - 0.00% 0.00%
Italy (IT) Gruppo bancario Mediobanca PSNL...HI44 O-SII - 0.00% 0.00%
Italy (IT) Gruppo bancario cooperativo ICCREA NNVP...4M97 O-SII - 0.00% 0.00%
Italy (IT) UniCredit Group 5493...5692 O-SII - 0.01% 0.01%
Latvia (LV) AS Citadele banka 2138...UO97 O-SII - 0.01% 0.01%
Latvia (LV) AS SEB banka 5493...GV07 O-SII - 0.01% 0.01%
Latvia (LV) Swedbank Baltics AS 9845...X660 O-SII - 0.02% 0.02%
Liechtenstein (LI) LGT Bank AG (LGT Group) 5493...2G89 O-SII - 0.02% 0.02%
Liechtenstein (LI) Liechtensteinische Landesbank AG 5299...LP72 O-SII - 0.02% 0.02%
Liechtenstein (LI) VP Bank AG MI3T...4Q14 O-SII - 0.02% 0.02%
Lithuania (LT) AB SEB bankas 5493...8J82 O-SII - 0.02% 0.02%
Lithuania (LT) AB Šiaulių bankas 5493...YU51 O-SII - 0.01% 0.01%
Lithuania (LT) Revolut Bank UAB 4851...TW40 O-SII - 0.02% 0.02%
Lithuania (LT) Swedbank AB 5493...HE59 O-SII - 0.02% 0.02%
Luxembourg (LU) BGL BNP Paribas S.A. UAIA...WE37 O-SII - 0.01% 0.01%
Luxembourg (LU) Banque Internationale à Luxembourg S.A. 9CZ7...BS50 O-SII - 0.01% 0.01%
Luxembourg (LU) Banque et Caisse d’Epargne de l’Etat Luxembourg R7CQ...1078 O-SII - 0.01% 0.01%
Luxembourg (LU) Clearstream Banking S.A. 5493...JJ44 O-SII - 0.01% 0.01%
Luxembourg (LU) Intesa Sanpaolo Bank Luxembourg S.A. 5493...S319 O-SII - - -
Luxembourg (LU) Société Générale Luxembourg TPS0...L873 O-SII - 0.01% 0.01%
Malta (MT) APS Bank plc 2138...CU10 O-SII - 0.00% 0.00%
Malta (MT) Bank of Valletta plc 5299...JF16 O-SII - 0.02% 0.02%
Malta (MT) HSBC Bank Malta p.l.c. 5493...1Z91 O-SII - 0.01% 0.01%
Malta (MT) MDB Group Ltd 2138...W403 O-SII - 0.01% 0.01%
Netherlands (NL) ABN AMRO Bank N.V. BFXS...XW11 O-SII - 0.01% 0.01%
Netherlands (NL) Bank Nederlandse Gemeenten 5299...OO93 O-SII - 0.00% 0.00%
Netherlands (NL) Coöperatieve Rabobank U.A. DG3R...WN62 O-SII - 0.01% 0.01%
Netherlands (NL) De Volksbank N.V. 7245...2I11 O-SII - 0.00% 0.00%
Netherlands (NL) ING Bank N.V. 3TK2...QE75 O-SII 0.01% 0.02% 0.02%
Norwegian Ministry of Finance (Norwegian Ministry of Finance) DNB ASA 5493...1414 O-SII - 0.02% 0.02%
Norwegian Ministry of Finance (Norwegian Ministry of Finance) Kommunalbanken AS I7ET...J389 O-SII - 0.01% 0.01%
Norwegian Ministry of Finance (Norwegian Ministry of Finance) Nordea Eiendomskreditt AS 5493...0618 O-SII - 0.01% 0.01%
Norwegian Ministry of Finance (Norwegian Ministry of Finance) Sparebank 1 Sør-Norge ASA 5493...M052 O-SII - 0.01% 0.01%
Poland (PL) BNP Paribas Bank Polska SA NMH2...CM63 O-SII - 0.00% 0.00%
Poland (PL) Bank Handlowy w Warszawie SA XLEZ...4793 O-SII - 0.00% 0.00%
Poland (PL) Bank Millennium SA 2594...8K78 O-SII - 0.00% 0.00%
Poland (PL) Bank Polska Kasa Opieki SA 2594...AY35 O-SII - 0.01% 0.01%
Poland (PL) Bank Polskiej Spółdzielczości SA BB3B...9R41 O-SII - 0.00% 0.00%
Poland (PL) ING Bank Ślaski SA 2594...VX41 O-SII - 0.01% 0.01%
Poland (PL) Powszechna Kasa Oszczedności Bank Polski SA P4GT...FR43 O-SII - 0.02% 0.02%
Poland (PL) SGB-Bank SA 2594...5P83 O-SII - 0.00% 0.00%
Poland (PL) Santander Bank Polska SA 2594...G361 O-SII - 0.01% 0.01%
Poland (PL) mBank SA 2594...AY35 O-SII - 0.01% 0.01%
Portugal (PT) Banco BPI 3DM5...4N92 O-SII - 0.01% 0.01%
Portugal (PT) Banco Comercial Português JU1U...ZV32 O-SII - 0.01% 0.01%
Portugal (PT) Caixa Central - Caixa Central de Crédito Agríco... 5299...TB26 O-SII - 0.00% 0.00%
Portugal (PT) Caixa Economica Montepio Geral 2138...R537 O-SII - 0.00% 0.00%
Portugal (PT) Caixa Geral de Depósitos TO82...FH57 O-SII - 0.01% 0.01%
Portugal (PT) LSF Nani Investments S.à.r.l. 2221...WQ08 O-SII - 0.01% 0.01%
Portugal (PT) Santander Totta SGPS 5493...VC58 O-SII - 0.01% 0.01%
Romania (RO) BRD - Groupe Societe Generale S.A. 5493...4238 O-SII - 0.01% 0.01%
Romania (RO) Banca Comercială Intesa SanPaolo Romania S.A. 5493...LZ18 O-SII - - -
Romania (RO) Banca Comercială Română S.A. 5493...8X90 O-SII - 0.01% 0.01%
Romania (RO) Banca Cooperatista Creditcoop 3157...0450 O-SII - - -
Romania (RO) Banca Română de Credite şi Investiţii S.A. 3157...RX82 O-SII - - -
Romania (RO) Banca Transilvania S.A. 5493...8896 O-SII - 0.03% 0.03%
Romania (RO) CEC Bank S.A. 2138...8W87 O-SII - 0.01% 0.01%
Romania (RO) Credit Europe Bank S.A. 5493...ER04 O-SII - - -
Romania (RO) Exim Banca Românească S.A. 6354...X605 O-SII - 0.01% 0.01%
Romania (RO) First Bank S.A. 5493...BQ46 O-SII - - -
Romania (RO) Garanti Bank S.A. 5493...EY46 O-SII - - -
Romania (RO) Libra Internet Bank S.A. 3157...HW38 O-SII - - -
Romania (RO) OTP Bank Romania S.A. 5299...UF61 O-SII - 0.01% 0.01%
Romania (RO) Patria Bank S.A. 5493...WI25 O-SII - - -
Romania (RO) Porsche Bank S.A. 5299...P324 O-SII - - -
Romania (RO) ProCredit Bank S.A. 5299...Q337 O-SII - - -
Romania (RO) Raiffeisen Bank S.A. 5493...8591 O-SII - 0.01% 0.01%
Romania (RO) Techventures Bank S.A. 5299...4924 O-SII - - -
Romania (RO) UniCredit Bank S.A. 5493...QS04 O-SII - 0.01% 0.01%
Romania (RO) Vista Bank Romania S.A. 5493...KH30 O-SII - - -
Slovakia (SK) Prima banka Slovensko, a.s. 3157...W 27 O-SII - 0.00% 0.00%
Slovakia (SK) Slovenská sporiteľňa, a.s. 5493...I 89 O-SII - 0.02% 0.02%
Slovakia (SK) Tatra banka, a.s. 3157...D587 O-SII - 0.01% 0.01%
Slovakia (SK) Všeobecná úverová banka, a.s. 5493...Z7 5 O-SII - 0.02% 0.02%
Slovakia (SK) Československá obchodná banka, a.s. 5299...4 62 O-SII - 0.01% 0.01%
Slovenia (SI) Intesa Sanpaolo 5493...L932 O-SII - 0.00% 0.00%
Slovenia (SI) Nova Ljubljanska Banka d.d. 5493...OW30 O-SII - 0.01% 0.01%
Slovenia (SI) OTP banka d.d 5493...BZ89 O-SII - 0.01% 0.01%
Slovenia (SI) SID - Slovenska izvozna in razvojna banka d.d. 5493...6F87 O-SII - 0.01% 0.01%
Slovenia (SI) UniCredit Banka Slovenija d.d. 5493...1F08 O-SII - 0.00% 0.00%
Spain (ES) Banco Bilbao Vizcaya Argentaria, S.A. K8MS...AZ71 O-SII - 0.01% 0.01%
Spain (ES) Banco Santander, S.A. 5493...AM13 O-SII 0.01% 0.01% 0.01%
Spain (ES) Banco de Sabadell, S.A. SI5R...RM20 O-SII - 0.00% 0.00%
Spain (ES) CaixaBank, S.A. 7CUN...FI87 O-SII - 0.01% 0.01%
Sweden (SE) Nordea Hypotek AB 5493...FO29 O-SII - 0.01% 0.01%
Sweden (SE) Notes to the table: 1) The ECB is not notifie... - O-SII - - -
Sweden (SE) Skandinaviska Enskilda Banken AB (SEB) F3JS...TN86 O-SII - 0.01% 0.01%
Sweden (SE) Svenska Handelsbanken AB NHBD...YZ31 O-SII - 0.01% 0.01%
Sweden (SE) Swedbank AB M312...1685 O-SII - 0.01% 0.01%
OSII/GSII Buffer Rates by Country
Bank Name LEI Code Type G-SII O-SII Status
Addiko Bank AG 5299...XD62 O-SII - - Active
BAWAG P.S.K. Bank für Arbeit und Wirtschaft und Österreic... 5299...R372 O-SII - 0.01% Active
Erste Bank der oesterreichischen Sparkassen AG 5493...FZ83 O-SII - 0.01% Active
Erste Group Bank AG PQOH...6792 O-SII - 0.02% Active
HYPO NOE Landesbank für Niederösterreich und Wien AG 5493...0Y27 O-SII - - Active
Hypo Tirol Bank AG 0W5Q...2R27 O-SII - - Active
Hypo Vorarlberg Bank AG NS54...FP35 O-SII - - Active
Oberösterreichische Landesbank AG 5299...X375 O-SII - - Active
RAIFFEISEN-HOLDING NIEDERÖSTERREICH-WIEN registrierte Gen... 5299...X537 O-SII - 0.01% Active
Raiffeisen Bank International AG 9ZHR...UG95 O-SII - 0.02% Active
Raiffeisenlandesbank Niederösterreich-Wien 5299...EE83 O-SII - 0.01% Active
Raiffeisenlandesbank Oberösterreich AG I6SS...3S50 O-SII - 0.01% Active
Steiermärkische Bank und Sparkassen AG 5493...7B03 O-SII - 0.00% Active
UniCredit Bank Austria AG D1HE...XG17 O-SII - 0.02% Active
Volksbanken Wien AG (for the consolidated situation of th... 5299...I904 O-SII - 0.00% Active

Capital stack

Capital Buffer Stack
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Across European countries, capital buffer requirements exhibit notable variations, primarily driven by the Countercyclical Capital Buffer (CCyB) and country-specific buffers for Globally or Other Systemically Important Institutions (GSII/O-SII). While some countries maintain a CCyB rate of 2.5%, others have set it at different levels, including 0%, 0.5%, 0.75%, 1%, 1.25%, 1.5%, 2%, and 2.25% (DATA CONTEXT: LATEST CCyB TABLE). The secondary components, particularly the CCyB and buffers for GSII/O-SII, reveal distinct national risk appetites and financial sector structures. Nordic countries like Denmark and Iceland, along with Croatia, show higher total buffers, largely due to elevated CCyB levels, suggesting a recent history of rapid credit growth or perceived heightened systemic risk. Conversely, countries like Italy, Luxembourg, and Austria have lower total requirements, with minimal or zero CCyB and modest GSII/O-SII buffers, indicating a more stable credit environment or less concentrated systemic risk. The absence of Systemic Risk Buffers (SyRB) and specific sub-categories (sSyRB) across all countries suggests that, in the last 12 months, the focus has been on broader macroprudential tools rather than institution-specific stress resilience measures.

Borrower-based measures

Overview

Section Summary
  • European countries, including Bulgaria, Croatia, and Cyprus, have implemented borrower-based measures (BBMs) such as restrictions on Loan-to-Value (LTV), Debt-Service-to-Income (DSTI), and loan maturity. These measures aim to curb excessive credit growth and household leverage in the residential real estate sector, thereby enhancing financial stability and mitigating risks from housing market downturns. (Source: https://www.centralbank.cy/en/financial-stability/macroprudential-policy-decisions/countercyclical-capital-buffer-ccyb)
  • The ongoing application and introduction of BBMs by these nations demonstrate a commitment to improving credit quality and promoting housing affordability. By limiting borrower exposure, authorities are proactively addressing potential over-indebtedness and fostering more sustainable housing markets, which reinforces the resilience of their financial systems against potential shocks. (Source: https://www.centralbank.cy/en/financial-stability/macroprudential-policy-decisions/countercyclical-capital-buffer-ccyb)
Adoption Count
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The adoption of borrower-based measures (BBMs) has seen a steady increase over the past 12 months, indicating a growing global focus on mitigating systemic financial risks. Countries are increasingly implementing these measures to address concerns related to excessive credit growth, particularly in the housing market, and to curb the build-up of household debt. The primary risks targeted by these policies include the potential for asset bubbles, increased vulnerability of households to economic downturns, and the subsequent impact on financial stability. This trend suggests a proactive approach by policymakers to prevent the recurrence of financial crises by managing credit cycles and ensuring the resilience of the financial system.
Active Measures Cross-Country Comparison
Latest reference data: 2026-08-01
In the last 12 months, borrower-based measures have been actively employed across various European countries to mitigate housing credit risks and achieve national financial stability objectives. For instance, Bulgaria introduced new restrictions on Loan-to-Value (LTV), Debt-Service-to-Income (DSTI), and loan maturity ratios, aiming to curb excessive credit growth and leverage in the residential real estate sector (SOURCES: https://www.bnb.bg/AboutUs/PressOffice/POPressReleases/POPRDate/PR202409111EN). Similarly, Croatia has implemented binding limits on LTV, DSTI, and loan maturity, targeting a more sustainable housing market (SOURCES: https://www.hnb.hr/en/core-functions/financial-stability/cnb-s-macroprudential-policy/consumer-lending-criteria). Cyprus continues to enforce LTV and DSTI measures to manage credit expansion and potential borrower over-indebtedness (SOURCES: https://www.centralbank.cy/en/financial-stability/macroprudential-policy-decisions/countercyclical-capital-buffer-ccyb, https://www.centralbank.cy/images/media/pdf/ENDirectiveCreditGrantingReviewProcesses2016.pdf). These measures collectively underscore a continental objective to build resilience against potential housing market downturns and ensure the stability of the financial system by preventing the accumulation of excessive household debt.
Latest Borrower-based Measure Decisions
Over the past 12 months, borrower-based measures have been implemented or maintained across several European countries, primarily aiming to mitigate credit risk and ensure financial stability in the real estate and lending sectors. Authorities have focused on controlling debt burdens relative to income, with objectives including managing the debt-service-to-income (DSTI) ratio for both individuals and legal persons, particularly in the context of real estate lending and buy-to-let investments. Similarly, loan-to-value (LTV) ratios have been a key focus, with considerations for first-time buyers and down payment requirements to prevent excessive leverage. The risks cited often revolve around the potential for rising interest rates impacting debt servicing capacity and the general credit risk associated with property ownership and investment. Some measures also address loan maturity to manage the duration of exposure.

LTV

LTV Measures (Loan-to-Value)
Latest reference data: 2026-08-01
Over the last 12 months, LTV limits and first-time buyer (FTB) exemptions have been actively managed across various European countries, primarily aiming to curb excessive mortgage lending and promote housing market stability. The objective is to prevent the buildup of systemic risk by ensuring borrowers have sufficient equity, thereby mitigating potential losses for lenders during economic downturns. While FTB exemptions are intended to facilitate homeownership for new entrants, a key risk is that they might inadvertently inflate demand and prices, potentially making housing less affordable in the long run. Some countries have introduced specific LTV adjustments, such as Romania lowering limits for investment properties, highlighting a targeted approach to manage risks associated with non-owner-occupied housing. The overall trend suggests a cautious approach to credit availability in the mortgage market.

DSTI

DSTI Measures (Debt Service-to-Income)
Content coming soon

DTI / LTI

DTI/LTI Measures (Debt-to-Income / Loan-to-Income)
Expert-verified: This table shows DTI/LTI measures with expert-verified data. Schema: Country, Type, Debt Counted, Legal Form, Standard Limit, Preferential Limit, Income Basis, Portfolio Limit, Nature of Breach, Exemptions, Regulation Link.

Reciprocation

Measures currently recommended for reciprocation
Reciprocation status by country

Country Profiles

Knowledge Graph

🧠 AI Analysis: Knowledge Graph Insights

The knowledge graph represents relationships between countries, measures, and policy patterns. This AI analysis compares graph-derived insights with table-based data to identify patterns, validate consistency, and highlight notable policy clusters.

Knowledge graph analysis is temporarily disabled for performance optimization.

About

Macro Policy Hub

An automated, AI-driven dashboard for tracking Macroprudential Policy (CCyB, SyRB, BBM) across the European Economic Area.

Business Value:
  • Time Efficiency: Reduces quarterly macroprudential reporting time from days to minutes by automating data retrieval, cleaning, and initial analysis. Real-time monitoring across 30+ EEA countries eliminates manual data collection.
  • Accuracy & Consistency: AI-validated data ensures accuracy and consistency. Expert corrections handle country-specific policy nuances. Structured extraction (regex + AI) reduces human error in data interpretation.
  • Cost Reduction: Eliminates hours of manual data entry, Excel manipulation, and cross-referencing. Scalable solution handles increasing data volumes without proportional cost increases.
  • Strategic Insights: AI-generated executive summaries enable quick decision-making. Cross-country comparison and trend analysis help identify policy patterns and anticipate future changes.
  • Operational Excellence: Standardized output ensures comparability. Unified dashboard for all macroprudential measures. Mobile accessibility supports remote work. Data portability enables further analysis.
Technology & Architecture

Technology Stack

Core Python, pandas
AI/ML LangChain, LangGraph, Gemini 2.5 Flash
Visualization Plotly
Frontend Jinja2, HTML/CSS/JS

Key Features

  • Multi-Pillar Monitoring (CCyB, SyRB, BBM, GSII/O-SII)
  • Country Profiles with comprehensive policy overview
  • Knowledge Graph Analysis for AI-enhanced insights and validation
  • AI-Driven Intelligence with Grounded Validation (using graph data)
  • Modern Mobile-Responsive UI
  • Robust ETL Pipeline

Data Sources

ESRB publications: CCyB dataset, Measures Overview (SyRB/BBM), Capital-Based Measures (GSII/O-SII).

System Architecture

Five-stage pipeline: Data Ingestion & ETL processes ESRB Excel files (CCyB, SyRB, BBM, GSII/O-SII) into Parquet storage with individual bank-level extraction and Supabase integration; Data Enrichment generates country profiles and knowledge graph relationships (countries, measures, banks) for enhanced AI context; BBM Processing extracts and validates structured LTV and DTI/LTI rules using regex and AI, supporting multiple limits/ranges; AI Analysis & Grounding uses LangGraph to orchestrate validation (extract claims → verify against data/charts/graph relationships → optional Google Search → refine with Gemini 2.5 Flash), including OSII/GSII bank-level analysis; Dashboard Layer renders HTML with embedded Plotly charts, interactive country/bank selectors, AI-generated insights, and optional Supabase-based dynamic data loading.

graph TD subgraph DataIngestion["Data Ingestion and ETL"] A["ESRB Data Source Excel Files"] -->|Download| B["Python ETL Pipeline"] B -->|"Clean, Normalize, Extract Banks"| C["Parquet Storage"] B -->|"Write Structured Data"| DB[("Supabase PostgreSQL DB")] end subgraph DataEnrichment["Data Enrichment"] C -->|"Country Data"| K["Country Profile Generator"] K -->|"Profiles"| L["Knowledge Graph Builder"] L -->|"Graph Data"| M["Country Profiles and Graph Data"] L -->|"Graph Context"| N["RAG Retriever"] K -->|"Write Profiles"| DB L -->|"Write Graph Data"| DB end subgraph BBMProcessing["BBM Processing"] C -->|"BBM Data"| O["LTV Extractor"] C -->|"BBM Data"| P["DTI/LTI Extractor"] O -->|"Extracted Rules"| Q["LTV Validator"] P -->|"Extracted Rules"| R["DTI/LTI Validator"] Q -->|"Validated Rules"| S["BBM Tables"] R -->|"Validated Rules"| S S -->|"Write BBM Rules"| DB end subgraph AICore["AI Analysis and Grounding"] C -->|"Retrieve Context"| D["LangGraph Validator"] H["Plotly Charts"] -->|"Chart Images"| D J["Google Search"] -->|"External Evidence"| D M -->|"Graph Context"| D N -->|"Retrieved Context"| E["Google Gemini 2.5 Flash"] S -->|"BBM Rules"| D D -->|"Raw Data and Images"| E E -->|"Draft Analysis"| D D -->|"Verified Output"| F["Final Analysis"] end subgraph Presentation["Dashboard Layer"] F --> G["Jinja2 Template Engine"] C -->|"Visual Data"| H M -->|"Country and Graph Data"| G S -->|"BBM Tables"| G DB -->|"Optional Dynamic Data"| G G --> I["HTML Dashboard"] H --> I end style A fill:#f9f,stroke:#333,stroke-width:2px style C fill:#f9f,stroke:#333,stroke-width:2px style DB fill:#3ecf8e,stroke:#333,stroke-width:3px style E fill:#bbf,stroke:#333,stroke-width:2px style D fill:#fef3c7,stroke:#333,stroke-width:2px style K fill:#fef3c7,stroke:#333,stroke-width:2px style L fill:#fef3c7,stroke:#333,stroke-width:2px style M fill:#f9f,stroke:#333,stroke-width:2px style N fill:#bbf,stroke:#333,stroke-width:2px style O fill:#d4edda,stroke:#333,stroke-width:2px style P fill:#d4edda,stroke:#333,stroke-width:2px style Q fill:#d4edda,stroke:#333,stroke-width:2px style R fill:#d4edda,stroke:#333,stroke-width:2px style S fill:#f9f,stroke:#333,stroke-width:2px style I fill:#bfb,stroke:#333,stroke-width:2px
License

This project is open-source, licensed under the Creative Commons Attribution-NonCommercial 4.0 International License (CC BY-NC 4.0).