The European Central Bank's Single Supervisory Mechanism (SSM) recorded a 19% increase in formal enforcement proceedings in 2024, according to the SSM's 2024 Annual Report on Sanctioning Activities published this year. The total number of proceedings reached 441, driven by 293 new proceedings opened during the year, while 182 administrative penalties were imposed and 220 proceedings remained ongoing at year end.
Pecuniary penalties — that is, cash fines — totalled €27.905 million across 140 separate penalty decisions, underlining the SSM's continued use of financial sanctions as a primary enforcement tool. The figures reflect a supervisory apparatus that is both broadening its reach in terms of case volumes and deepening its focus on specific categories of institutional failure.
GOVERNANCE FAILURES DOMINATE PROCEEDINGS
Internal governance deficiencies accounted for 55% of all proceedings opened in 2024, making this the dominant category by a substantial margin. The SSM's emphasis on governance reflects a long-standing supervisory concern that weaknesses in board oversight, management accountability, and internal control frameworks represent the root cause of many other compliance failures within significant and less significant institutions across the euro area.
Reporting breaches and large exposure violations accounted for significant additional proportions of the caseload. Reporting failures — which encompass late, incomplete, or inaccurate submission of supervisory data — are taken seriously by the SSM because they undermine the supervisor's ability to monitor risk in real time. Large exposure violations, meanwhile, indicate that some institutions are taking on concentrated positions that exceed the limits designed to prevent single-counterparty losses from destabilising a bank.
The report also highlighted the proportion of proceedings directed at natural persons: individuals — typically executives or members of management bodies — accounted for 54% of all proceedings. This signals that the SSM is increasingly pursuing personal accountability rather than limiting enforcement to institutional-level penalties, a trend that aligns with the broader European regulatory philosophy of ensuring that responsible individuals bear consequences for governance failures.
SCALE OF FINES AND ONGOING PROCEEDINGS
The €27.905 million in pecuniary penalties imposed during 2024 was spread across 140 decisions, implying an average fine of approximately €199,000. Individual penalty sizes vary considerably depending on the severity and duration of the breach, the size of the institution, and whether aggravating or mitigating circumstances are present. The SSM has discretion to calibrate penalties within the ranges set by the Capital Requirements Directive and national transposing legislation.
With 220 proceedings still ongoing at the close of 2024, further enforcement actions and financial penalties are expected to materialise in 2025 as the backlog is resolved. The SSM has made clear that it views sanctioning as an integral component of its supervisory toolkit, complementing ongoing supervisory dialogue and — in severe cases — early intervention measures.
The annual report is published by the ECB as part of its accountability obligations to the European Parliament and serves as a reference document for compliance officers, legal advisers, and risk managers at supervised institutions across the banking union. The data provides a public benchmark against which institutions can assess their own governance and compliance standards relative to those of their peers.