I have seen that and a bit of controversy around it
Promise-to-pay on its own is not a concession… agreeing to pause the contractual dunning process & associated late-fees, however, can be easily seen as one — materiality concerns should apply here, though - banks could easily put an optional clause of ‘dunning-process & collecting/waiving late fees at sole discretion of the bank’ into the contract at which point there no longer is a concession-event vs pre-agreed optionality
Financial difficulties is where you also would want to differentiate: is a delay of 2-3 months, below 90dpd, credible auto-cure by the end really a situation of financial difficulties? Here it is easy to define materiality thresholds that pass the EBA guidelines
JST/ Inspectors I speak with are typically a bit more concerned with banks being 'laissez faire' with this, than with the actual risk. I have seen cases where the bank had no policy or controls around this and then it resulted in a finding on potential underestimation of forbearance / S2 -- proper policy writing and guidance to relationship managers should close the perceived governance gap
There is a clear understanding of bad incentives: if you punish banks for agreeing with clients in this way by enforcing a cure period that is worse than 'do nothing', it clearly creates a conflict, that should be put on the table when arguing against an overly conservative view. But careful that not all 'silent acceptance' of delays are then afterwards equated with active concessions