Guiding principles

The credit institutions are primarily responsible for the initial and ongoing
assessment of the suitability of the members of the management body and key
function holders.

The supervisor expects that the appointee will disclose all relevant proceedings to
the best of their knowledge and will be transparent and honest with the ECB and the
national competent authority (NCA). Any document requested by the supervisor
must be presented to the extent possible. Otherwise, the reason why it was not
possible to obtain and present such information or document should be clearly
explained.

This Guide, which describes the policy stances, supervisory practices and processes
applied by the competent authorities within the Single Supervisory Mechanism
(SSM), is designed as a practical tool which will be updated and developed over
time.

The policy stances contained in the Guide are without prejudice to national law.
However, where possible, the ECB and the NCAs strive to interpret national rules
consistently with these policy stances.

Fit and proper assessments are carried out on a case-by-case basis and this Guide
should serve as a practical tool only. Therefore, in each case, the assessment will
come down to an analysis of the individual situation and supervisory judgement.
The supervisory practices described in the Guide respect the principle of
proportionality, namely that they are commensurate with the size, systemic
importance and risk profile of the credit institutions under supervision and the
efficient allocation of finite supervisory resources.

The suitability assessment conducted by the competent authorities is prudential and
preventive in nature and highly dependent on the available information. It is distinct
from criminal or administrative infringement procedures.

The fit and proper assessment feeds into the ongoing supervision of the governance
of a credit institution. Fit and proper decisions may contain provisions that require a
follow-up as part of ongoing supervision. Moreover, ongoing supervision may in turn
lead to the reassessment of members of the management body, highlight gaps with
regard to collective suitability or provide insights in the context of reappointments

The final package namely the ECB guide to fit and proper assessments, the updated Fit and Proper Questionnaire and the feedback statement have been published on 8 December 2021.