Regulation (EU) 2024/1252 on Critical Raw Materials in Romania (2026): Practical Steps for Financial Institutions Assessing Supply‑chain and ESG Exposure

Regulation (EU) 2024/1252, the EU Critical Raw Materials Act, is directly applicable EU law, and 2026 is the year in which Romanian institutions with exposure to raw‑materials supply chains should put a structured compliance and due‑diligence programme in place. Although the regulation is primarily an industrial and strategic‑autonomy instrument, it carries real consequences for banks, insurers and non‑bank financial institutions that finance, insure or hold exposure to projects, companies and sectors affected by critical and strategic raw materials. This guide converts the EU text, and Romania’s related national measures, into an actionable project plan: who should act, what to assess, what documentation to prepare, and how to evidence a disciplined approach to supervisors and counterparties.

It is written for compliance officers, CFOs, heads of risk and external advisers who need practical steps rather than abstract commentary. Every regulatory statement below is anchored to a primary source so your team can verify each claim before it goes into a filing or a credit file.

Executive summary and immediate actions

Teams that treat Regulation (EU) 2024/1252 Romania analysis as a structured risk‑and‑exposure project, rather than a last‑minute filing exercise, will spend far less and face fewer questions from supervisors and counterparties. The following first‑180‑day actions apply across all three institution types, with sector nuances flagged.

• Days 0–30 (scoping): Confirm whether, and how, your institution is exposed (through financing, insurance, investment or collateral linked to critical or strategic raw‑materials sectors), appoint a single accountable owner, and review supervisory expectations with BNR for banks and ASF for insurers and most NBIs.
• Days 0–30 (gap analysis): Map the relevant obligations and themes in the EU text against your current risk, reporting, data and governance to produce a prioritised gap list.
• Days 30–60 (data build): Begin building the data sets needed to identify and monitor exposure; identify system changes early because IT work is the longest lead item.
• Days 60–90 (governance): Update policies, committee mandates and internal control attestations; schedule board/management briefings.
• Days 90–180 (valuation and audit): Finalise valuation and impairment methodologies where supply‑chain risk is material, commission external verification where evidence is required, and assemble a documentation pack.
• Banks: prioritise exposure mapping, credit‑risk and collateral integrity first.
• Insurers: prioritise underwriting exposure, provisions and valuation methodology documentation first.
• NBIs: prioritise data integrity, reconciliations and governance evidence first.

Quick overview: Regulation (EU) 2024/1252 and its relevance in Romania

Regulation (EU) 2024/1252, commonly known as the Critical Raw Materials Act, entered into force in 2024 and is directly applicable EU law. Because it is a regulation rather than a directive, its core provisions apply in Romania of their own force, while national measures may be adopted to support certain aspects of implementation (for example permitting, designation of national authorities and alignment of domestic procedures). The regulation sets EU‑level benchmarks and a framework for securing the supply of critical and strategic raw materials, strategic projects, supply‑chain monitoring and recycling. You can read the full regulation on EUR‑Lex (CELEX:32024R1252).

For financial services teams, the practical takeaway is that the regulation is not a traditional prudential reporting instrument. Its relevance to banks, insurers and NBIs is indirect but significant: it reshapes risk, strategic‑project pipelines and ESG and supply‑chain expectations for the companies and sectors you finance, insure or invest in. Your assessment should therefore focus on exposure identification, risk management and the documentation that evidences a sound approach, rather than assuming a new mandatory filing to a Romanian financial supervisor.

What Regulation (EU) 2024/1252 analysis actually changes for financial institutions

At a working level, institutions should expect the analysis to touch four areas: the data you collect about counterparties and sectors, the way you assess and evidence risk and valuation where supply‑chain exposure is material, the governance and internal controls around those processes, and the documentation you can produce for supervisors, auditors and counterparties. The exact relevance depends on your business mix, so your gap analysis should map applicable themes to concrete data fields, owners and systems. Harmonised European supervisory expectations and guidelines published by the European Banking Authority (EBA) remain the right reference point for banks when interpreting risk‑management and ESG‑related supervisory expectations.

Romanian national measures: status and what to track

Romania has undertaken legislative work related to the application of Regulation (EU) 2024/1252. A legislative proposal addressing measures for the application of the regulation has been tabled in Parliament; its text and status can be followed through the Senate legislative file, and any formal adoption and entry‑into‑force details are published in the Monitorul Oficial, accessible through legislatie.just.ro. Because a legislative proposal is not the same as an enacted and in‑force law, verify the current status and any published dates directly against these official sources before committing deadlines or assumptions to your project plan.

Where national measures designate competent Romanian authorities or permitting procedures, those sit alongside the directly applicable EU text. For financial institutions, the authorities most relevant to your existing regulatory relationships are the National Bank of Romania (BNR) for credit institutions and the Financial Supervisory Authority (ASF) for insurers and a large part of the non‑bank financial sector. Track the published instructions and expectations of whichever supervises your institution.

Distinguishing the EU text from the national measures

Because the substantive framework flows from the directly applicable EU regulation, national measures should not alter the EU‑level objectives, but they can shape procedural detail, designate national bodies and support permitting for strategic projects. Where the national measures are not yet enacted or their technical detail is not published, treat the corresponding parts of your plan as provisional and build in a revision checkpoint. The firm recommendation is simple: anchor your analysis to the EU text now, and keep the national procedural assumptions flexible until the Romanian instruments are confirmed.

Dimension-by-dimension comparison: banks vs insurers vs non‑bank financial institutions

The single most useful planning tool for Regulation (EU) 2024/1252 Romania analysis is a side‑by‑side view of how the themes land differently across the three institution types. Use the table below to assign the right starting point and the right owners, then read the analysis that follows.

Relevance and exposure. The firm position: do not start work until you have confirmed where your portfolio touches critical or strategic raw‑materials sectors. Banks financing mining, processing, recycling or downstream manufacturing clients sit clearly within scope of the analysis under BNR supervision; insurers have underwriting and investment exposure under ASF; NBIs such as lenders and leasing companies are predominantly ASF‑supervised. A wrong scoping assumption cascades into wasted system work.

Risk and data. Banks should assume the most granular exposure and concentration data on affected borrowers. Insurers’ assessment centres on underwriting exposure, provisioning and investment risk. NBIs face a lighter but still material load. In all three cases, the correct first move is to translate the relevant themes into data fields with named owners.

Capital and cost. For banks the dominant cost is risk‑management uplift and exposure analysis; for insurers it is underwriting and valuation work; for NBIs it is data integrity and documentation. Budget to your dominant driver rather than spreading resources evenly.

Governance, valuation and systems. Governance uplift is often proportionally largest for NBIs, while valuation and audit evidence can dominate for insurers. IT impact is highest for banks. Across the board, start IT scoping on day one, it consistently determines whether milestones are met.

Decision framework: which assessment track to run

• Choose the bank‑track (exposure and credit‑risk first) when the institution is deposit‑taking, has a large balance sheet, is subject to BNR consolidated supervision, or finances clients in raw‑materials value chains.
• Choose the insurer‑track (underwriting and valuation first) when the institution is supervised by ASF and carries material underwriting or investment exposure to affected sectors.
• Choose the NBI‑track (data and governance first) when the business is lending, leasing or microfinance, prioritise governance, reconciliation and external audit evidence over complex modelling.
• Apply the hybrid rule when more than one supervisor is involved or the group runs cross‑sector activities: run parallel workstreams but coordinate a single documentation pack with reconciled balances and shared assumptions.

Assessment checklist and 12‑month timeline for Regulation (EU) 2024/1252 Romania analysis

The plan below assigns owners, deliverables and sample timeframes. Treat the days as a template and recalibrate against any published Monitorul Oficial dates once confirmed via legislatie.just.ro.

Days 0–30: scoping, ownership and gap analysis

• Head of Compliance (owner): confirm exposure against the EU text and your portfolio; review supervisory expectations.
• CFO: appoint a single accountable programme owner and approve an initial budget envelope.
• Head of Risk: produce a prioritised gap list mapping themes to data, systems and controls.
• Deliverable: one‑page scoping memo and a ranked gap register.

Days 30–90: data collection and risk builds

• Head of Accounting / Finance (owner): define the required data sets and reconciliations; identify source systems.
• IT lead: scope system changes, data lineage and controls, begin build on the longest‑lead items.
• Deliverable: data dictionary mapped to themes, with named field owners and a build schedule.

Days 60–120: accounting and valuation adjustments

• Head of Accounting (owner): finalise valuation and impairment methodologies where exposure is material and document them; confirm any IFRS interactions using the IFRS Foundation standards where valuation and audit evidence intersect with financial reporting.
• Insurers, actuarial function: prepare provisioning calculations and supporting memoranda where relevant.
• Deliverable: signed‑off valuation memorandum and reconciliation schedules.

Days 60–120: governance and policy updates

• Head of Compliance (owner): update policies, committee mandates and internal control attestations.
• Board / management: receive briefing and formally approve the assessment approach.
• Deliverable: updated policy set and a documented control attestation framework.

Days 120–180: audit and external verification

• Internal Audit (owner): test the new data, reconciliations and controls before external review.
• External Auditor: provide verification or an auditor letter over the balances and methodologies that require independent evidence.
• Deliverable: internal audit report and external verification letter.

Days 180–365: documentation pack and stakeholder liaison

• Head of Compliance (owner): assemble a documentation pack and manage supervisor or counterparty queries.
• CFO: sign off final balances and any cover letter to a supervisor.
• Deliverable: complete, reconciled documentation pack.

Documentation list (template):

• Cover letter to the supervisor or counterparty.
• Exposure mapping and valuation memorandum (methodology, assumptions, sources).
• Reconciliation schedules tying reported figures to the ledger.
• Risk report (insurers) or exposure and credit‑risk pack (banks).
• Internal control attestation.
• Internal audit report and external auditor letter.

Governance, evidence and documentation standards supervisors expect

Supervisors assess not only the numbers you present but the evidence that supports them. BNR, ASF and, for harmonised prudential and risk‑management expectations, the EBA all look for a clear, traceable chain from source data to any reported figure. In practice, the strongest documentation shares a common anatomy: documented valuation and risk methodologies, reconciliation schedules that tie reported balances to the accounting records, internal control attestations signed by accountable officers, and an audit opinion or external verification where independent evidence is appropriate. Reference BNR’s published requirements at bnr.ro and ASF’s requirements at asfromania.ro as you build each component.

Templates and the red flags that trigger reviews

Two templates do most of the heavy lifting. The first is a valuation and exposure memorandum that states the methodology, the key assumptions, the data sources and the sign‑off chain. The second is a cover letter that summarises what is enclosed, confirms the balances are reconciled, and names the responsible officers. Common red flags that attract scrutiny include unreconciled balances between documentation and the ledger, valuation assumptions that are undocumented or inconsistent across related files, missing control attestations, and a pack that lacks independent verification where it is appropriate. Clear, cross‑referenced documentation is the single most reliable way to shorten any review.

Supervisory expectations, enforcement context and risk mitigation

Romanian supervisors have an established administrative toolkit under their governing legislation. For banks, BNR can apply supervisory measures and administrative sanctions; for insurers and most NBIs, ASF holds equivalent powers, including supervisory measures, remediation orders and administrative fines. Where the EU regulation does create direct obligations for specific economic operators, enforcement responsibilities may fall to the national authorities designated under Romania’s implementing measures rather than the financial supervisors. The expectation is that any enforcement will be proportionate to the size of the institution or operator and the seriousness of the breach. Confirm the applicable supervisory powers against the published instructions at bnr.ro and asfromania.ro, and the EU‑level obligations in the regulation itself.

Mitigation is straightforward and inexpensive relative to the cost of a problem later: test your data and reconciliations internally, set aside a remediation budget so fixes can be made quickly, and engage your supervisor or key counterparties proactively where exposure is material. Early, documented engagement almost always produces a better outcome than an issue discovered later during review.

Next steps and advisory support

Regulation (EU) 2024/1252 Romania analysis rewards early, structured action. The practical path is to confirm exposure, build the data and reconciliations, finalise valuation and governance evidence, and assemble a single reconciled documentation pack. Download the one‑page implementation checklist, and for tailored, advisory support on building a disciplined assessment programme, contact the adviser via the Global Law Experts advisor profile. For related guidance, see the companion resources on preparing regulator‑ready IFRS financial statements for Romanian supervisory filings, the compliance checklist for non‑bank financial institutions in Romania, and how valuation and audit reports support regulatory submissions, alongside the Financial Services practice area, Romania overview.

Sources

1. Regulation (EU) 2024/1252 (EUR‑Lex)
2. Senat, related legislative file
3. Legislatie.just.ro / Monitorul Oficial
4. National Bank of Romania (BNR)
5. Financial Supervisory Authority (ASF) Romania
6. European Banking Authority (EBA)
7. Ministry of Finance (Romania)
8. IFRS Foundation