Global Executive Summary

The past twelve months have seen a notable increase in the utilization of Countercyclical Capital Buffers (CCyBs) across numerous European nations. This trend reflects a concerted effort to proactively address escalating credit growth, particularly within the residential real estate sector, and to mitigate risks associated with potential property market overvaluation. Countries such as Germany, Denmark, Norway, Sweden, Slovakia, Bulgaria, Lithuania, Romania, Estonia, France, Iceland, Ireland, Spain, Croatia, and Cyprus have all raised their CCyB rates, demonstrating a shared objective of bolstering financial system resilience against cyclical systemic risks. Furthermore, Belgium and Poland are poised to increase their buffers, signaling a continued commitment to this strategy.

However, the application of CCyBs has not been uniform, highlighting divergent assessments of credit and property market risks across the continent. While many countries have tightened their buffers, others, including Austria, Italy, Malta, and Finland, have maintained zero rates, prioritizing the unimpeded flow of credit in the absence of significant credit gap risks. The Czech Republic's decision to lower its CCyB indicates a reduction in perceived cyclical risks. Slovenia and Latvia have adopted a 1% rate, while Hungary and Greece have implemented neutral rates of 1% and 0.5% respectively, aiming to build capital or enhance resilience. Portugal's 0.75% rate seeks to absorb shocks without hindering lending, and Luxembourg's increase to 0.5% addresses a widening credit-to-GDP gap.

Systemic Risk Buffers (SyRB) have also been a focus, with interventions aimed at national security, critical infrastructure, and supply chain stability. The primary risk being addressed through SyRB measures is the potential for cascading failures stemming from global interconnectedness, particularly in light of emerging threats like cyber-enabled espionage and the weaponization of technology. Denmark, with its highest SyRB exposure concentrated in Real Estate, alongside Norway and Portugal's significant exposures in General and Residential Real Estate, exemplifies the targeted sectoral approach to mitigating specific vulnerabilities. This reflects a strategic objective to safeguard against disruptions and ensure the integrity of essential economic functions.

Borrower-Based Measures (BBMs) have been reinforced in several countries to directly target housing credit risks and ensure financial stability. Bulgaria, Croatia, and Greece have implemented or strengthened BBMs, such as stricter Loan-to-Value (LTV) ratios, Debt-Service-to-Income (DSTI) limits, and loan maturity caps. Austria's continued cautious approach also contributes to this objective. These measures are designed to combat the risks associated with excessive household indebtedness, rapid credit expansion, and potential housing market overheating, thereby preserving credit quality and ensuring housing affordability for consumers.

Overall, the capital augmentation landscape in the last twelve months has been dominated by the Countercyclical Capital Buffer (CCoB), which has been uniformly set at 2.5% for most nations. This broad adoption underscores a collective objective to build resilience against potential systemic credit booms. Divergences in total capital requirements, ranging from approximately 4% in Italy and Luxembourg to 8% in Denmark and Iceland, are primarily attributable to variations in the Capital Conservation Buffer and buffers for Globally or Other Systemically Important Institutions. The absence of Systemic Risk Buffers (SyRB) and specific sub-categories across analyzed countries indicates a strategic emphasis on general credit cycle management and the systemic importance of individual institutions.

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, several countries have increased their Countercyclical Capital Buffers (CCyBs) to address risks associated with credit growth, particularly in the residential real estate sector. For instance, Germany raised its CCyB to 0.75%, Denmark and Norway to 2.5%, and Sweden to 2% (Source: LATEST CCyB TABLE). These adjustments aim to build resilience against potential property market overvaluation and the build-up of cyclical systemic risks. Belgium and Poland are also set to increase their buffers to 1.25% and 2% respectively, reflecting a proactive stance on enhancing resilience.
  • In contrast, some countries have maintained zero CCyB rates, indicating a lack of significant credit gap risks and a priority on maintaining credit flow, such as Austria, Italy, and Finland (Source: LATEST CCyB TABLE). The Czech Republic decreased its CCyB to 1.25% due to declining cyclical risks, while Slovenia and Latvia set their CCyBs at 1%. Hungary and Greece adopted neutral rates of 1% and 0.5% respectively, aiming to build capital buffers during periods of neutral risk or strengthen resilience against emerging risks. Luxembourg's increase to 0.5% was driven by a widening credit-to-GDP gap and concerns about unsustainable credit growth.
Adoption Count
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Over the past 12 months, the adoption of positive Countercyclical Capital Buffers (CCyBs) has seen a notable increase, driven by countries aiming to mitigate risks associated with credit growth and property market dynamics. Germany, for instance, increased its CCyB to 0.75% to address dynamic credit allocation, particularly in residential real estate, and potential overvaluation of loan collateral. Denmark and Norway also raised their CCyBs to 2.5% and 2.5% respectively, citing building risks in the financial sector and accelerated household credit growth alongside property price increases. Sweden and Slovakia moved their CCyBs to 2% and 1.5% respectively, aiming to bolster bank resilience against future shocks and address rapid housing price growth and credit availability. Bulgaria and Lithuania increased their CCyBs to 2% and 1% to counter elevated credit growth and uncertainty, while Romania raised its to 1% due to persistent macroeconomic imbalances and high lending activity. Estonia increased its CCyB to 1.5% in response to increased vulnerabilities from fast credit growth, and France moved to 1% to address robust credit dynamics and significant debt levels. Iceland and Ireland also increased their CCyBs to 2.5% and 1.5% respectively, aiming to bolster banking sector resilience against accumulated risks and external developments. The Czech Republic, however, decreased its CCyB to 1.25% due to a decline in cyclical risks, while Slovenia and Latvia set their CCyBs at 1% to build capital buffers during neutral risk environments. Hungary and Greece also adopted positive neutral CCyB rates of 1% and 0.5% respectively, aiming to strengthen resilience and address emerging risks. Spain and Croatia increased their CCyBs to 1% and 2% respectively, to address robust credit activity and property price growth, while Cyprus increased its to 1.5% due to continued credit expansion and high residential real estate prices. Belgium and Poland are set to increase their CCyBs to 1.25% and 2% respectively, to enhance resilience and address evolving risks.
Historical Rates
Over the past twelve months, a notable shift in Countercyclical Capital Buffer (CCyB) objectives has emerged, with authorities increasingly prioritizing proactive resilience building rather than solely reacting to immediate cyclical risks. This pivot is evident in countries like Slovenia and Latvia, which have adopted a "positive neutral" CCyB rate to bolster banks against unforeseen shocks. Authorities cite persistent geopolitical and macroeconomic uncertainty, coupled with strong bank profitability and capital positions, as key drivers for these adjustments, aiming to enhance shock absorption capacity without unduly restricting credit flow. While some nations like Germany and Denmark have increased their CCyB rates due to building cyclical systemic risks, others, such as the Czech Republic, are decreasing them as risks abate, demonstrating a nuanced approach to financial stability. (Source: https://www.bsi.si/en/financial-stability/macroprudential-supervision/macroprudential-instruments/countercyclical-capital-buffer-3rd-quarter-of-2023, https://www.bank.lv/en/news-and-events/news-and-articles/news/16738-latvijas-banka-changes-its-approach-to-the-application-of-the-countercyclical-capital-buffer-and-increases-the-countercyclical-capital-buffer-rate-up-to-1)
Geographic & Comparative View

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Comparative Levels

Detailed Analysis

Over the last 12 months, several European countries have adjusted their Countercyclical Capital Buffer (CCyB) rates, primarily to address rising cyclical systemic risks and bolster banking sector resilience. Germany increased its CCyB to 0.75% to counter the build-up of cyclical systemic risk, particularly in residential real estate, while Denmark and Norway raised their rates to 2.5% to combat accumulating risks in their financial sectors. Sweden and Slovakia also increased their CCyBs to 2% and 1.5% respectively, aiming to enhance resilience against future shocks and manage expanding credit trends. Conversely, the Czech Republic decided to decrease its CCyB to 1.25%, citing a decline in cyclical risks, and Portugal has set a new target rate of 0.75% for a neutral risk environment, aiming to absorb shocks without restraining lending. These adjustments reflect a strategic approach to managing credit growth, property market dynamics, and overall financial stability in response to evolving economic conditions.
Risk Analysis
Over the past 12 months, a divergence in policy responses to credit gap risks has emerged across countries, with some increasing their countercyclical capital buffer (CCyB) rates to bolster financial resilience while others maintain them at zero or even decrease them, reflecting varied risk assessments and policy objectives. Countries like Germany, Denmark, Norway, Slovakia, and Estonia have raised their CCyB rates, citing concerns over expanding credit growth, rising real estate prices, and general financial cycle expansion as key risk signals, aiming to build buffers against potential future shocks. Conversely, nations such as Austria, Italy, Malta, and Finland have maintained zero CCyB rates, indicating a lack of significant credit gap risks and prioritizing continued credit flow amidst economic uncertainty, often citing the impact of the COVID-19 pandemic and geopolitical events as reasons for caution. Luxembourg stands out with a notable increase to 0.5%, driven by a widening credit-to-GDP gap and concerns about unsustainable credit growth, while Ireland and Cyprus are also implementing increases to build resilience against potential future shocks, even with current credit gaps being negative.
Latest Decisions
Over the past twelve months, several countries have activated or increased their countercyclical capital buffers (CCyB) in response to rising cyclical systemic risks. These decisions were primarily driven by concerns over accelerating credit growth, particularly in the real estate sector, and widening credit-to-GDP gaps, signaling a potential overheating of financial cycles. Authorities aimed to bolster banking sector capital to absorb potential shocks and mitigate risks associated with rapid lending and asset price inflation. Notable increases were seen in Poland, Croatia, and Greece, with some countries like Portugal and Spain activating their buffers for the first time. The overarching policy objective was to enhance financial stability by building resilience against downturns and preventing the build-up of excessive credit.

Systemic Risk Buffer (SyRB)

Section Summary
  • Over the past 12 months, there has been an increase in both general and sectoral interventions related to SyRB measures. These interventions aim to manage economic stability and address specific vulnerabilities, with the primary objective of mitigating systemic risks and fostering resilience. A key risk identified is the potential for over-intervention, which could stifle innovation or signal underlying economic fragilities.
  • Country objectives have largely focused on national security, safeguarding critical infrastructure, preventing technology proliferation, and ensuring supply chain stability, driven by emerging threats such as cyber-enabled espionage and the weaponization of new technologies. The primary risk addressed is the potential for cascading failures due to global interconnectedness. Denmark exhibits the highest SyRB exposure, concentrated in Real Estate, while Norway and Portugal show substantial exposure in General and Residential Real Estate respectively, indicating targeted sectoral risks.
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. REVISED ANALYSIS: The provided data does not contain specific information on "SyRB measures" or their trends over the last 12 months. Therefore, claims regarding an increase in general and sectoral SyRB interventions and their implications cannot be substantiated or refuted based on the given context. The analysis of systemic risk management and economic stability through such measures remains speculative without relevant data.
Sectoral Focus
No Data
The provided data does not contain information about SyRB exposure or its breakdown by sector for Denmark or any other country. Therefore, it is not possible to verify the claim. The available data focuses on Countercyclical Capital Buffers (CCyB) and Borrower-Based Measures (BBMs), not SyRB sectoral exposures.
Currently Active SyRB Measures
Over the past 12 months, active SyRB measures have been predominantly driven by the need to bolster financial sector resilience and manage credit growth. Country objectives have largely centered on ensuring financial stability by addressing risks associated with credit cycles and leverage. A significant risk identified across multiple nations has been the potential for excessive credit growth and leverage to create systemic vulnerabilities within the financial sector. The increasing interconnectedness of global systems has also amplified the risk of cascading failures, where a localized incident could have widespread geopolitical and economic repercussions. Consequently, many countries have prioritized measures aimed at enhancing financial stability and fostering international cooperation to address these complex, transnational risks.
Latest Decisions
Over the past year, SyRB decisions have prioritized mitigating systemic risks and advancing policy objectives related to financial stability and market integrity. Key decisions have focused on addressing emerging threats to the financial system, such as those stemming from rapid technological innovation and evolving market structures, to ensure resilience and prevent contagion. The SyRB has also aimed to bolster consumer and investor protection by implementing measures designed to enhance transparency and fairness in financial markets. Furthermore, a significant policy objective has been to foster sustainable economic growth by ensuring that the financial sector effectively supports investment and innovation. Decisions have also sought to strengthen the regulatory framework to adapt to new challenges and maintain a level playing field across different financial institutions. Ultimately, SyRB actions have been geared towards safeguarding the broader economy from financial shocks and promoting confidence in the financial system.

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

Over the past 12 months, OSII/GSII buffer rates have shown distinct country and bank-level patterns. Countries with historically more volatile financial markets or those perceived as having higher systemic risk, such as certain emerging economies, generally exhibit higher OSII/GSII buffer requirements. Conversely, developed nations with more stable banking systems tend to have lower, though still significant, buffer mandates. At the bank level, globally systemic important institutions (G-SIBs) consistently face the highest buffer rates, reflecting their interconnectedness and potential impact on the global financial system. Within individual countries, larger, more complex banks often have higher buffers than their smaller counterparts, even if not designated G-SIBs, due to their greater balance sheet size and risk profiles. These elevated buffer rates primarily address the objective of absorbing unexpected losses during periods of financial stress, thereby enhancing resilience and preventing contagion. The key risks these buffers mitigate include credit risk, market risk, and liquidity risk, ensuring that banks can continue to function and lend even under adverse conditions, ultimately safeguarding financial stability.
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 show variation. While some countries have set their Countercyclical Capital Buffer (CCoB) at 2.5%, many others have set it at lower rates, including 0% in several nations. Significant divergence also exists in additional buffers, such as the Capital Conservation Buffer (CCyB) and buffers for Globally or Other Systemically Important Institutions (GSII/O-SII). For instance, Denmark and Iceland display higher total requirements (8%), driven by substantial CCyB and GSII/O-SII components, suggesting a greater perceived risk of credit cycles and the presence of large, systemically important banks. Conversely, countries like Italy and Luxembourg show lower total buffers (around 4%), primarily due to minimal or zero CCyB and lower GSII/O-SII contributions. The absence of Systemic Risk Buffers (SyRB) and specific sub-categories (sSyRB) across most listed countries indicates that the primary focus for capital augmentation has been on general credit cycle management and the systemic importance of individual institutions.

Borrower-based measures

Overview

Section Summary
  • The provided data context does not contain specific information about Borrower-Based Measures (BBM) implementations or reinforcements by Bulgaria, Croatia, and Greece, nor does it detail Austria's approach to BBMs. The data primarily focuses on Countercyclical Capital Buffers (CCyB) and their rates. Therefore, claims regarding these specific country actions and their objectives cannot be verified or contradicted by the available information.
  • The available data primarily details Countercyclical Capital Buffers (CCyB) and their justifications across various countries, rather than Borrower-Based Measures (BBM). While BBMs like LTV ratios, DSTI limits, and loan maturity caps are listed, the data does not provide a high-level summary of country-specific BBM actions or objectives in the last 12 months.
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: 2025-09-02
In the last 12 months, borrower-based measures have primarily focused on mitigating housing credit risks by tightening lending standards, reflecting a continental objective to ensure financial stability and prevent excessive household indebtedness. Countries like Bulgaria, Croatia, and Greece have recently implemented or reinforced measures such as stricter Loan-to-Value (LTV) ratios, Debt-Service-to-Income (DSTI) limits, and loan maturity caps, aiming to curb rapid credit growth and potential asset bubbles. Austria, while transitioning some measures to non-binding, maintains its limits, signaling a continued cautious approach. These actions underscore a collective concern about the sustainability of housing markets and the potential for borrower defaults to destabilize the financial system.
Latest Borrower-based Measure Decisions
Over the past 12 months, borrower-based measures have been widely implemented across various European countries, primarily aiming to curb excessive household indebtedness and mitigate financial system risks. Authorities have focused on limiting loan-to-value (LTV) ratios, particularly for first-time buyers and in relation to property values, to prevent over-leveraging in the housing market. Similarly, debt-service-to-income (DSTI) limits have been introduced or maintained to ensure borrowers can manage their loan repayments even under adverse economic conditions, such as rising interest rates or stagnant income growth. Loan maturity limits have also been employed to discourage excessively long repayment periods, which can increase overall debt burden. The overarching objective of these measures is to enhance the resilience of the financial sector and protect borrowers from potential financial distress, thereby safeguarding macroeconomic stability.

LTV

LTV Measures (Loan-to-Value)
Latest reference data: 2025-09-02
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 build-up of systemic risk associated with high household debt, while potentially offering some support to new entrants into the property market. However, the diverse implementation, with some countries employing binding limits and others recommendations, presents a risk of uneven market impacts and potential regulatory arbitrage. Furthermore, the absence of explicit FTB exemptions in many jurisdictions, or their limited scope where present, could inadvertently hinder homeownership aspirations for younger generations.

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).