Amending certain Directives as regards the further development of capital market integration and supervision within the Union

Europes strategic autonomy requires deeper EU capital markets. The FBF therefore supports the MISP and urges a swift, ambitious agreement. Competitiveness should be embedded as a core objective. The Lamfalussy process should be respected: Level 1 principle based; Level 2 specifying implementation modalities and minimum parameters; Level 3 setting parameter levels and remaining optional.

INREV welcomes the opportunity to provide feedback on the European Commissions EU rules to foster integration and efficient supervision, part of the broader Savings and Investments Union initiative. As the European association for the non-listed real estate investment industry, INREV represents a sector that relies structurally on cross-border capital formation and long-term institutional investment.

As was highlighted in the Draghi and Letta reports, the key objectives of the Savings and Investment Union (SIU) should be the mobilization of European retail savings into productive investments and the development of supplementary (funded) pensions as the two most important levers to create deeper capital markets.

BNY welcomes the Market Integration Package (MIP) and its policy objectives of deepening the single market, reducing fragmentation, and unlocking cross-border efficiencies for savers, issuers and intermediaries. BNY fully supports the proposals in the Master Directive that would allow depositary banks to provide depositary services for investment funds on a cross-border basis.

The International Securities Lending Association (ISLA) welcomes the Commissions proposal to amend the UCITS framework to further develop capital market integration. ISLA recognises the critical need for the urgent structural reforms highlighted in the Draghi and Letta reports in 2024 to bolster the EUs global competitiveness and economic resilience, particularly through the enhancement of market liquidity…

To Whom it May Concern, Business & Science Poland (BSP) welcomes the possibility to provide feedback on the provisions proposed in the Directive that is part of the Market Integration Package. Please find attached our position paper serving as feedback in the consultation process, based on expertise provided by our sectoral members.

Assogestioni expresses its appreciation for the initiative of the European Commission aimed at simplifying and streamlining key aspects of the Union legislative framework governing asset management within the Market Integration and Supervision Package (MISP).

MEDEF welcomed the draft European MISP text. It is an important step towards strengthening the integration and competitiveness of European financial markets to the benefit of businesses. In the current context, it is essential to have a high level of dambition. The US and several Asian squares are making rapid progress in adapting their regulatory framework to financial and technological transformations.

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The Luxembourg Bankers Association (ABBL) welcomes the opportunity to comment on the European Commissions Market Integration and Supervision Package (MISP). As the representative voice of Luxembourgs banking and financial services industry, the ABBL brings together a broad membership spanning banks, investment firms, assetservicing providers and other financial intermediaries, many of which operate crossborder and…

INVERCO is the Spanish Association of Collective Investment Schemes and Pension Funds. It is a non-profit organization representing more than 980.7 billion in assets under management, channelling savings from nearly 27 million unit-holder accounts in Investment Funds and Investment Companies and 10.4 million in Pension Funds.

FAIR, representing a collective of more than 150 organisations engaged in impact finance, welcomes the Commissions proposal to further advance the integration of EU capital markets and enhance supervisory convergence as part of the Savings and Investments Union.

The German Alternative Investments Association (Bundesverband Alternative Investments e.V. - BAI) welcomes the opportunity to give feedback on the proposals to foster market integration and efficient supervision. As an industry association we represent more than 300 national and international members active in the institutional alternative investments sector (i.e.

We agree on the importance of revising the current EU framework to effectively address the remaining barriers to financial market integration. In this context, we appreciate the overall approach undertaken by the MISP Directive, particularly its focus on barriers stemming from the lack of harmonisation of EU rules and supervisory practices.

Introduction This contribution is submitted on behalf of the European Trustee and Depositary Forum (ETDF), a pan-European industry forum representing depositaries, trustees, custodians and fiduciary service providers across the European Union.

France Invest broadly supports the European Commissions proposals to revise the AIFMD and the CBDF Regulation and calls for their swift adoption. AIFMD review France Invest supports the Commissions objective of further harmonising the regulatory framework governing AIFMs across Member States. In particular, we welcome the proposed harmonisation of authorisation procedures.

CECA (Spanish Association of Savings and Retail Banks) welcomes the opportunity to comment on the proposal for a Directive of the European Parliament and of the Council amending Directives 2009/65/EC, 2011/61/EU and 2014/65/EU as regards the further development of capital market integration and supervision within the Union. Please find attached our considerations.

AMF Italia welcomes the opportunity to provide comments on the proposal referred to above. Generally, we consider the European Commissions analysis of the obstacles affecting the competitiveness of EU markets to be well founded.

France Post-Marché (FPM), the association representing post-trade stakeholders in France and playing a significant role in the overall competitiveness of the European market, welcomes the ECs initiatives aimed at strengthening the integration, competitiveness and efficiency of the Single Market for capital, while making several recommendations to ensure the operational consistency of the reforms, regulatory…

The LPEA believes the EU Single Market is a key platform to strengthen the growth and competitiveness of the EU Private Equity (PE) and Venture Capital (VC) industry. PE/VC managers rely on efficient cross-border fundraising, a predictable regulatory environment, and flexible capital deployment to deliver value, serve investors, and scale the next generation of European champions.

The Association of International Banks in Germany e.V. (VIB) welcomes the opportunity to comment on the Market Integration Package (MIP) presented by the European Commission on 4 December 2025. The MIP forms part of the Savings and Investments Union (SIU), through which the European Commission aims to remove barriers to cross-border capital market activities and further deepen the integration of the Single Market.

DUFAS welcomes the European Commissions ambition to take further steps towards creating a well-functioning, integrated, and internationally competitive European capital market through the Market Integration Package (MIP).

The French asset management association (AFG) welcomes the initiative of the Market Integration and Supervision Package aiming at promoting simplification, tackling barriers to cross-border activities and contributing to shape a more integrated European Union. AFG takes the opportunity to develop its views on the various topics developed in this initiative in the attached document. 1.

The Market Integration and Supervisory Package (MISP) forms a central component of the European Commissions (EC) broader strategy to strengthen the efficiency, competitiveness, and integration of the European Unions (EU) capital markets.

The Confederation of Swedish Enterprise welcomes the opportunity to contribute to this consultation on the Market Integration Package under the Savings and Investments Union. We support the overall objective of strengthening Europes capital markets and improving the mobilisation and allocation of capital across the EU.

The CNMV supports the objectives pursued by the Market Integration Package, in particular the reduction of fragmentation, the strengthening of market integration and supervisory convergence, and the enhancement of the Unions competitiveness.

As announced in the ‘Savings and Investments Union’ strategy, this directive aims to: promoting more integrated, substantial and efficient EU capital markets by removing regulatory, operational and supervisory barriers that hinder key EU capital markets operators and infrastructure, modernising and simplifying EU capital markets rules and reducing administrative burdens.

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We welcome the approach aimed at promoting greater regulatory uniformity in the European market through the transition from a directive to a regulation. This choice appears consistent with the objective of ensuring more effective harmonisation of regulated activities throughout the Union, reducing differences in interpretation and application between Member States.

The Swedish Investment Fund Association (SIFA) supports the overarching objective of strengthening the internal market by removing barriers to cross-border activity. However, measures taken under MISP must genuinely reduce fragmentation and costs, not introduce additional layers of complexity. SIFA calls for a proportionate and cost-efficient approach to market integration.

The CNMV's Advisory Committee has been set by the Spanish Securities Markets Law as the consultative body of the CNMV. It is composed by market participants, and its opinions are independent from those of the CNMV.

BVI and its members are committed to shaping a competitive EU Single Market for financial services and dismantling the remaining obstacles to effective cross-border operations. Hence, while supporting the political objectives of the Market Integration Package, it is important that the specific policy measures remain targeted and proportionate, addressing genuine obstacles without introducing additional complexity or…

While we have no opinion on the proposed technical simplifications for market operators, we note that, as with MiFID I, some of the proposals could weaken large European players, without it being clear that smaller ones will be placed in a position to grow. This was one of the strategic shortcomings of MiFID I, which MiFID II attempted to rectify without truly succeeding.

The Savings & Investments Union initiative is timely and relevant. However, from the standpoint of ECSPR, its full potential for market integration and direct wealth creation remains underutilised. ECSPR opens up new pathways for retail investors to directly participate in the growth of Europes SMEs and startups, facilitating broad-based wealth creation beyond traditional financial instruments.

Natixis Investment Managers welcomes the call for evidence of the European Commission on Savings and Investments Union : fostering integration, scale and efficient supervision in the single market We share and strongly support the drive to further integrate European capital markets. We support its ambition to facilitate market-driven consolidation, a strong asset management sector and supervisory convergence.

Efficient financial markets that can effectively support the substantial financing needs of strategic sectors are essential to strengthen the Unions economy and global standing. We encourage the European Commission to adopt, in defining the necessary regulatory changes, an outcome-driven approach focused on growing EU financial markets, increasing their attractiveness to both institutional and retail investors…

Euronext welcomes the opportunity to comment on Savings and Investment Union and the real need to adopt EU rules to foster market integration and efficient supervision. To unlock the full potential of the EUs 13 trillion in private savings and strengthen its global competitiveness, the European Union must urgently address several fundamental barriers that have led to a fragmented capital market.

BNY welcomes the opportunity to respond to the European Commissions call for evidence in relation to a planned legislative initiative entitled Savings and Investments Union: Fostering integration, scale and efficient supervision in the single market.

Swiss Finance Council members include some of the largest global asset and wealth management firms, many of which have substantial activities and investments in the EU. Our members operate as investment product manufacturers, distributors, and advisors, serving EU clients from both within the EU and on a cross-border basis, and non-EU clients investing in the EU.

Swiss Finance Council members include some of the largest global asset and wealth management firms, many of which have substantial activities and investments in the EU. Our members operate as investment product manufacturers, distributors, and advisors, serving EU clients from both within the EU and on a cross-border basis, and non-EU clients investing in the EU.

EFPA SPAINS Response on ECS Call for Evidence on Savings and Investments Union Fostering integration, scale and efficient supervision in the single market EFPA Spain is the operative member association in Spain of EFPA, a standards-setting body operating within the European financial services sector and the association of over 100,000 qualified financial advisors, all of them certificate holders, renewed yearly…

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The European Central Securities Depositories Association (ECSDA) welcomes the opportunity to respond to the Call for evidence for an impact assessment Savings and Investments Union fostering integration, scale and efficient supervision in the single market, in advance of the more detailed contribution that will be provided with the response to the Targeted Consultation on integration of EU Capital Markets.

We strongly welcome the initiative to further deepen the European capital market with the Savings and Investment Union. The need to qualify European savers in capital market investors is undisputed. The EU must take into account and involve advisory companies as necessary partners. Without their engagement in direct contact with customers, the transformation process will not succeed.

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The Federation of European Securities Exchanges (FESE) believes that the success of the Savings and Investments Union (SIU), critical to addressing the persistent gap between Europes economic potential and its actual performance, will depend on progress across three interconnected pillars of EU capital markets: 1. stimulating investment and expanding capital pools; 2.

The European Financial Planning Association (EFPA) is a standards-setting and qualifications-accrediting body operating within the European financial services sector. Established to serve the interests of both professional financial advisors and their clients, EFPA aims to raise public awareness of its members' activities and ensure their adherence to the professions ethical and regulatory standards.

Euroclear fully agrees with the need to continue to improve the efficiency of European post-trade infrastructure and ensure it is fit for the next evolution of capital markets. The Commissions initiative to foster integration, scale and efficient supervision in the single market is an opportunity to create conditions for market-driven solutions that will advance EU competitiveness and the Savings and Investments…

Blockchain for Europe (BC4EU) welcomes the European Commissions initiative to assess the potential for more integrated supervision of crypto-asset service providers (CASPs), aligned with the goal of strengthening the EU single market and further integrating capital markets. Effective and consistent supervision is essential to reduce fragmentation, enhance market integrity, protect users, and support innovation.

The European Federation of Financial Advisers and Financial Intermediaries (FECIF), representing over 300,000 financial professionals, 30 million clients, and 3 trillion in investable assets across the EU and EEA, welcomes the European Commissions consultation on the state of capital market integration and effective supervision in capital markets.

The European Federation of Financial Advisers and Financial Intermediaries (FECIF), representing over 300,000 financial professionals, 30 million clients, and 3 trillion in investable assets across the EU and EEA, welcomes the European Commissions consultation on the state of capital market integration and effective supervision in capital markets.

We strongly support the objectives of the EU Savings and Investment Union as an important tool to close the significant funding gaps we are facing. Against this backdrop, we welcome the opportunity to share our views on how more integrated and efficient EU capital markets can be achieved.

The Investment Association represents 250 investment managers, a third of whom are headquartered in the EU, and who collectively operate from 642 offices across the EU. Our members put 10.6 trillion to work in the global economy, representing 37% of the 28.6 trillion in assets managed in Europe.

Insurance Europe welcomes the ECs effort and ambition to build a Savings and Investments Union (SIU). European insurers can play a key role in achieving the SIU goals: they provide protection to citizens and businesses, help people save for old age, are a major long-term investor in the EU economy with 9.5trn, invested in equity, corporate and sovereign bonds.

We welcome the Savings and Investment Union initiative that empowers citizens to invest in their future, channel capital into EU businesses and enhance the depth, effectiveness and connectivity of EU capital markets.

The Spanish Chamber of Commerce considers it positive to advance the development of a Union of Savings and Investments, which mobilises savings more effectively, in particular by supporting retail participation in the capital market through simple and cost-limited investment and savings products, and allowing EU companies to have more investments.

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AFEP, the French Association of Large Companies, is happy to contribute to this call for evidence to address issues related to European supervision. The Commission indicates that it will assess ways to achieve more efficient and unified supervision of capital markets, as indicated in the Competitiveness Compass and in the Savings and Investments Union Communication.

Aéma Groupe welcomes the opportunity to provide feedback and makes the following recommendations, detailed in the document enclosed: 1. Removing market barriers: The introduction of the European passport for funds has been an important step towards disseminating and distributing investment products throughout the European Union.

German (re)insurers strongly support the objectives of the Savings and Investments Union and welcome the Commissions initiative to further integrate European capital markets and assess ways to improve supervision in the EU.

The French asset management association (AFG) welcomes the ECs call for evidence on capital markets integration and supports its objectives for a competitive asset management sector, a more efficient supervision and a more standardized trading and post-trading ecosystem. Please see below our proposals. 1.

Deutsches Aktieninstitut welcomes the EU Commissions evident commitment to developing capital markets in the European Union and strengthening their integration. As thoroughly analysed, liquid and efficient capital markets are essential for the innovation and competitiveness of European companies. Without robust capital markets, financing the digital and sustainable transformation will not succeed.

In this statement we intend to set out the exchange industries view of the Savings and Investment Union initiative. In summary: Simplification and burden reduction are good objectives. Developing principles-based regulation going forward can help achieve this. The push to go further than international standards often harms this goal. Consolidation of financial market infrastructure should be led by market forces.

SME Financing The input from a bank lending perspective in the context of the SIU Consultation would be in the area of SME lending. SMEs face limited access to the capital markets to raise financing. In this scenario bank lending proves key to ensure sustained access to finance for SMEs.

Welcomes the proposal for a Savings and Investment Union; The proposal addresses many relevant aspects as well as the need for a Capital Markets Union and the issue of banking union. Sweden has a tradition of channelling private savings into investments and thus a great deal of experience on the benefits and challenges of the system.

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The Confederation of Swedish Enterprise supports the Commissions goal to strengthen the capital markets within the EU under the frameworks of an effective Savings and Investments Union. We share the ambition to improve how capital is mobilised and allocated across the EU. In our view, this must go hand in hand with preserving the integrity of well-functioning national frameworks.

(1) OFI INVEST is fully in favour of a union of scourge and investment. Today, as has been pointed out in all the reports, there is too much fragmentation in the capital markets, which limit the financing of the major investment needs of the European economy at a time when the scourge is very abundant and invests too often outside the European Union.

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With regard to banking and financial services, there is still a very complex and often uneven regulatory framework both between Member States and between large banking groups and Less Significant Institutions, the former being supervised by the ECB and/or adopting advanced models for calculating capital requirements, and the others by national authorities.

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Accountancy Europe welcomes the opportunity to respond to the European Commissions Call for Evidence on Regulation fostering EU market integration and efficient supervision, aimed at advancing the development of a Savings and Investments Union (SIU). Please refer to our attached feedback note/pdf for our full recommendations.

ACA is the Association des Compagnies dAssurances et de Réassurances du Grand-Duché de Luxembourg, the Luxembourg Insurance and Reinsurance Association. As such ACA will not address the issues on market-infrastructures and asset managers as insurers and reinsurers are more indirectly impacted.

ANASF welcomes the European Commission's initiative to develop rules that promote market integration and more efficient supervision. We believe that, in order to achieve this goal, it is essential to address the obstacles that still prevent a truly competitive and open capital market. The main obstacles faced by financial advisors are of a fiscal and legislative nature.

The VVO welcomes ECs effort and ambition to build a Savings and Investments Union (SIU). European insurers can play a key role in achieving the SIU goals: they provide protection to citizens and businesses, help people save for old age, are a major long-term investor in the EU economy with 9.5trn, invested in equity, corporate and sovereign bonds.

Union Investment welcomes the opportunity to provide feedback to the European Commissions (EC) Call for Evidence (CfE) in addition to the parallel DG FISMA consultation. For the purposes of the CfE, we would like to highlight three key aspects: UCITS investment limits: There is currently an unlevel playing field between ETFs, for which a 20% (exceptionally 35%) issuer limit may apply and actively managed funds which…

We welcome the initiative of the European Commission. I discuss the priorities identified and some of the elements of the argument. It cannot be disputed that the fragmentation of actors ‘between the Member States’, i.e. their very ‘national’ dimension is a weak point in the EU’s financial ecosystem, fragmentation in the sense of the ‘multiplicity’ of actors of all sizes is rather a strong point.

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Intercontinental Exchange operates a derivatives exchange and a CCP in the Netherlands. We are very concerned that the Commission is considering applying so-called "open access" to ETDs. This would have the effect of stifling product innovation in ETDs and would likely fragment trading liquidity, increasing costs for end users.

The European Association for Investors in Non-Listed Real Estate Vehicles (INREV) welcomes the opportunity to respond to the Commission's Call for Evidence on Savings and Investment Union - EU rules to foster market integration and efficient supervision. We hope our attached comments will make a constructive contribution to this important topic.

The Commissions impact assessment confirms that fragmentation remains one of the most persistent barriers to fully integrated EU capital markets. National regulatory and supervisory silos continue to drive up costs, limit investment opportunities, and hinder market-driven consolidationultimately preventing the single market from reaching its full potential.