Germany's New Route for Cross-Border Credit Claims in ECMS

The Deutsche Bundesbank has detailed how its counterparties can use credit claims governed by the law of another euro-area member state as collateral for refinancing operations. The claims would be handled through the Eurosystem Collateral Management System (ECMS), the shared platform for administering assets across the euro area, using the correspondent central banking model (CCBM).

In this model, a German-based counterparty pledges the claim at its home central bank (HCB) — the Bundesbank — while the responsible correspondent central bank (CCB) in the member state whose law governs the claim manages it in ECMS and carries out the eligibility check at submission.

The Bundesbank said counterparties interested in using these credit claims as non-marketable collateral should contact its support team for credit claims. Such claims can be used with selected central banks from the beginning of 2026, once the mandatory customer tests have been successfully completed.

The announcement matters because national procedures for credit claims differ from country to country, and the cross-border route may incur fees for transfer, administration and custody of collateral that vary by the central bank acting as CCB.

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ECMS, CCBM and the Country-by-Country Collateral Reality

What ECMS Changes for Collateral Management

ECMS is designed to replace the existing patchwork of national collateral administration systems with a single Eurosystem platform. For German counterparties, the practical effect is a more standardised way to submit and manage assets — but the eligibility of each credit claim still depends on the correspondent central bank in the country whose law applies. That CCB, not the Bundesbank, decides whether a claim qualifies at submission.

Why the CCBM Route Remains Subject to Local Rules

The CCBM has long been the mechanism for moving collateral across euro-area borders without physically transferring assets. What the Bundesbank's notice underlines is that even with ECMS harmonising administration, the underlying credit claims remain governed by national legal frameworks. Counterparties therefore need individual, country-specific approaches rather than one uniform process — which is exactly what the Bundesbank's guidance suggests.

The Costs and Timeline for German Counterparties

Adoption is not automatic. The Bundesbank requires mandatory customer tests before the claims can be used, and availability from the beginning of 2026 is limited to selected central banks. Fees may also apply for transfer, administration and custody of collateral, and they depend on which central bank acts as CCB. That means the economic value of the arrangement will vary by jurisdiction and by the costs charged by the CCB in question.

Practical Steps for Bundesbank Counterparties Before 2026

  • Contact the Bundesbank's support team for credit claims early to clarify eligibility for credit claims governed by the law of another euro-area member state, as the Bundesbank advises.
  • Complete the mandatory customer tests before the start of 2026 if you intend to pledge foreign-law credit claims via ECMS, since use is conditional on passing them.
  • Check whether each central bank you plan to use as CCB is among the selected central banks available from the beginning of 2026; availability is not universal at launch.
  • Quantify fees charged for transfer, administration and custody of cross-border credit claims by the relevant CCB, and weigh them against the liquidity benefit of added collateral.
  • Build country-specific procedures for each governing law in your collateral pool, because eligibility checks and national processes for credit claims differ by member state.

Risk & Opportunity Assessment

Commercial RiskMediumCross-border use may incur transfer, administration and custody fees that vary by CCB, and national procedures for credit claims require country-specific handling, adding operational cost.
Competitive RiskLowAccess is open to all Bundesbank counterparties on equal terms, so the change does not structurally favour one institution; however, banks with existing cross-border collateral infrastructure may adopt it faster.
Regulatory RiskMediumEligibility is decided by the CCB under the governing law of the member state, and use is conditional on completing mandatory Bundesbank customer tests and being accepted by selected central banks from 2026.
Reputation RiskLowThe notice is a routine operational disclosure from the Bundesbank about collateral eligibility and carries no conduct, compliance or market behaviour implications.
Technology DisruptionMediumECMS replaces national collateral administration with a single Eurosystem platform, requiring counterparties to adapt systems and processes and to pass mandatory customer tests before first use.
Commercial OpportunityMediumGerman counterparties gain access to a broader pool of non-marketable collateral by pledging credit claims governed by other euro-area laws at their home central bank, beginning in 2026.