Lower capital threshold, unchanged leverage requirement
The ECB set the requirements through its Supervisory Review and Evaluation Process, known as SREP. Its new decision replaces the previous one and sets Commerzbank Group's additional total-capital requirement, or P2R, at 2.10%, including at least 1.18% in common equity tier 1 capital, or CET1.
Applying the decision to the bank's June 30, 2026, position puts its pro forma CET1 minimum, known as the MDA threshold, at 10.26% of risk-weighted assets. That is a reduction of 0.03 percentage points.
The threshold comprises a 4.5% CET1 minimum, the reduced 1.18% CET1 portion of P2R, a 2.5% capital conservation buffer and a 1.25% buffer for other systemically important institutions. The latter two buffers are unchanged. A countercyclical buffer currently at 0.77% and a sectoral systemic risk buffer currently at 0.06% make up the remaining components.
The separate additional requirement for excessive leverage, P2R-LR, remains at 0.1%, where it has stood since 2023. Commerzbank reported a leverage ratio of 4.3% in June 2026, compared with the resulting requirement of 3.1%.
A second annual reduction
ECB Banking Supervision's Pillar 2 table, last updated February 20, 2026, lists Commerzbank's P2R at 2.25% for both 2024 and 2025, followed by 2.15% for 2026. The newly announced 2027 requirement extends the decline that began with the 2026 decision.
For comparison, the table lists Deutsche Bank's P2R at 2.65% in 2024, 2.90% in 2025 and 2.85% in 2026. Commerzbank's 2.10% requirement for 2027 is materially below the 2026 level for Germany's largest listed bank, though the figures apply to different years.
Commerzbank CEO Bettina Orlopp attributed the second consecutive reduction to the continuing strength and stability of the bank's business model, as well as its profitable growth and disciplined risk management. She said the buffer above the MDA threshold supports both financing for growth and the bank's shareholder distribution policy.
Capital position and stress-test context
Commerzbank's CET1 ratio was 14.4% at the end of June 2026. In its August 6 half-year report, the bank put its buffer above the then-applicable MDA threshold of around 10.3% at 409 basis points. It also reported record first-half net profit of €1.8 billion, up about 40% from a year earlier, and a record net return on tangible equity of 12.6%.
Stress-test results also feed into SREP. In the adverse scenario of the 2025 EBA/ECB test, Commerzbank's fully loaded CET1 ratio declined by 412 basis points to 9.6% at the end of the test period in 2027. The comparable decline in the 2023 test was 464 basis points, to 9.5%. Under the transitional regime, the 2025 test produced a decline of 484 basis points to 10.5%.
Shareholder returns and 2030 targets
For the 2026 financial year, Commerzbank plans to return around €3.2 billion to shareholders, according to its half-year report. The plan is based on a net profit target of at least €3.4 billion and a payout of 100% of net profit after AT-1 coupon payments and before extraordinary items. Dividends are intended to account for at least 50% of the payout.
As part of that capital return, the bank applied in July 2026 for a further share buyback of up to €1.2 billion. ECB approval was already in place when Commerzbank published its August 6 report.
The bank continues to target a CET1 ratio of 13.5% by 2030 under its Momentum strategy. In a May 18, 2026, statement outlining its Momentum 2030 goals, it also targeted annual revenue of €16.8 billion, net profit of €5.9 billion and a net return on tangible equity of 21% by 2030. Its cost-income ratio targets are 43% including compulsory contributions and 41% excluding them.
The May statement also set out an intention to return roughly half of the bank's market capitalization at that time to shareholders by 2030.
