Competitiveness in the single banking market

The EC report on the competitiveness of the banking sector is MISSING very important issues: INCREASING PAYOUTS: According to EBA data (Risk Assessment Reports) EU banks paid out EUR 521 bn to shareholders in 2017-2025 via dividends and share buybacks. They plan to pay out EUR 117.3 bn in 2026 (= EUR 638.5 bn in 2017-2026). Payouts have been rapidly increasing, with most payouts during 2023-2025 (EUR 279 bn).

The National Association of Cooperative Banks (KZBS), representing the cooperative banking sector in Poland, welcomes the publication of the European Commissions communication on competitiveness of the Banking Sector and the Single Market in Banking.

Revolut welcomes the Communication and shares its diagnosis of a sector that is resilient and profitable, yet fragmented along national lines and held back by persisting complexity. Serving 30 EEA markets gives us first-hand experience of how remaining national barriers continue to fragment the Single Market. We therefore support the ambition of the upcoming Banking Competitiveness package.

The EACB welcomes the release of the Commission's Communication on the competitiveness of the EU Banking sector. We stress the importance of this holistic review of the prudential framework as current constraints of the EU regulatory framework have concrete repercussions on the real economy and the ability of the EU to face the significant challenges ahead.

We acknowledge and fully agree with the analysis that investment firms contribute to the depth and diversity of EU capital markets by providing liquidity, allocating capital and supporting equity and debt issuance and that unjustified obstacles in the regulatory framework must be addressed.

EBA CLEARING's response to the European Commissions Communication on the Competitiveness of the Banking Sector and the Single Market in Banking. We would like to raise the following points for the Commissions consideration. Pan-European shared infrastructures are key enablers of integration in the Single Market.

Unipol welcomes the opportunity to provide feedback on the EU Commissions Communication on Competitiveness of the Banking Sector. As an insurance-led conglomerate with a leading participation in a significant bank, we support the Commissions approach, which integrates many of the recommendations put forward by Draghi and Letta to build a more competitive banking sector.

AMAFI welcomes the European Commissions assessment of the prudential framework applicable to investment firms and broadly shares its conclusion that IFR/IFD generally functions well, while improvements remain possible in terms of proportionality, simplification, supervisory convergence and international competitiveness.

Finance Iceland strongly supports the Commissions objective of simplifying the regulatory framework and reducing unnecessary complexity and administrative burden. Europe has built a strong and resilient financial regulatory framework. Continued attention to its effectiveness, proportionality and coherence can help ensure that the framework also supports Europes capacity to compete, invest and grow.

INBONIS welcomes the Commissions recognition that the prudential treatment of unrated corporates is of great importance for the EU banking framework. Since 1 January 2025, CRR3 enables the Standardised Approach to reduce Risk-Weighted Assets (RWA) from 100% to 75% for corporate exposures with a BBB rating assigned by External Credit Assessment Institutions (ECAIs) supervised by ESMA and recognised by EBA.

Dear Sir or Madame, Qivalis is an electronic money institution in formation, based in Amsterdam and established by a consortium of European banks. We have applied to De Nederlandsche Bank for authorisation as an electronic money institution under the Dutch Financial Supervision Act. Once authorised, we intend to issue a euro-denominated e-money token under the Markets in Crypto-Assets Regulation.

We welcome the European Commissions initiative to review European banking regulation. It must strengthen competitiveness while safeguarding financial stability through measurable reductions in regulatory complexity and administrative burdens. Simplification must deliver tangible relief without introducing additional requirements.

Dear Commissioners, I am writing to provide a consolidated submission comprising three documents: (i) the ReReFund nonobjection (ii) ReReFunds response to the Commissions findings, (iii) a comparative analysis of the USA and EU High Yield Debt Markets.

Urząd Komisji Nadzoru Finansowego (Eng. Polish Financial Supervision Authority) welcomes the opportunity to provide opinion on the Commissions Communication regarding the competitiveness of the European banking sector. Please find the feedback statement attached.

As the Chamber of Commerce and Industry for Munich and Upper Bavaria, we call for: Regulatory proportionality through higher thresholds and a separate small banking regime strengthens Level 2 and Level 3 regulation significantly reduces international competitiveness through adequate capital requirements preserves economic growth and international competitiveness as a shared responsibility

Filed in German · English published by the European Commission

The factoring and commercial finance industry strongly supports the Commission's objective of building a more competitive, integrated and efficient European financial system. We believe that future reforms should: 1. recognize factoring and supply chain finance as strategic tools for improved competitiveness and growth; 2.

Comments provided in this HYS do not supersede the EBF response to the EC consultation of 19th April 2026. The EBF welcomes the ECs Communication on bank competitiveness and reiterates its call for an ambitious banking package. The EC has identified the right challenges to EU bank competitiveness and set a direction going forward.

BNY welcomes the European Commissions Communication on the competitiveness of the EU banking sector. BNY would like to highlight four points that BNY believes are insufficiently covered in the Communication. 1. We agree with the Commissions observation that many rules continue to apply irrespective of size or business models, resulting in unnecessary complexity and administrative burden for banks.

The European Principal Traders Association (EPTA) represents Europe's leading principal trading firms and market makers. Our members provide liquidity, support price discovery and facilitate risk transfer across EU financial markets. EPTA welcomes the Commission's recognition that investment firms play an important role in supporting market liquidity, cross-border investment, price discovery and capital formation.

ABI shares the goal of strengthening competitiveness of the banking sector to boost the ability of European banks to finance real economy and encourages the European Commission (EC) to set ambitious objectives, as the current juncture requires decisive action. The EC assessment and proposed actions are considered broadly sharable.

The European Aerospace, Security and Defence Industries Association (ASD) wishes to express concern on two regulatory obstacles that are limiting the ability of European banks to finance the defence industry, especially SMEs in the defence supply chain, at the moment when Europe needs this financing most.

BNP Paribas welcomes the Communication of the European Commission dated 17 July 2026 as a major step forward, and the opportunity offered to share feedback. The Commission rightfully recognises the banking sector as a key driver of a strong and growing EU economy, both as a primary source of financing and as a fundamental enabler of the Savings and Investment Union.

The Swiss Finance Council (SFC) welcomes the July 2026 Communication on the Competitiveness of the EU Banking Sector and the Single Market in Banking (Communication) and the opportunity to comment. Swiss financial institutions engage in the EU as long-standing partners in support of its strategic objectives, providing capital, investment expertise and financial services that complement those of EU banks while adding…

Febelfin wishes to express support for the general messages of the Commission Communication on the Competitiveness of the Banking Sector and the Single Market in Banking. The Communications acknowledgement of the strategic role of the banking sector is very positive.

Our association welcomes the European Commissions renewed focus on strengthening the competitiveness of the European banking sector. A strong, competitive and well-functioning banking sector is essential to supporting investment, economic growth and financial stability across the European Union.

Guarantee banks provide guarantees to finance promising projects carried out by small and medium-sized enterprises in the commercial and professional sectors. The collateral provided by the guarantee banks constitutes a full collateral for all commercial banks and reduces the capital needs of credit institutions.

Filed in German · English published by the European Commission

The Association of Proprietary Traders (APT), represents 24 proprietary trading firms in the Netherlands and welcomes the European Commissions report on the competitiveness of the EU banking sector and, in particular, its recognition of the need to review the EU prudential framework for investment firms (IFR/D), to land on a more proportionate, risk-sensitive and internationally competitive regulatory framework.

The Central Association of German Crafts represents one million craft businesses employing around six million people. Many of the businesses are micro and small enterprises, which rely mainly on regional banks and savings banks for financing. In the attached opinion, you will find the ZDH’s proposals on how this type of funding can continue to be secured and facilitated.

Filed in German · English published by the European Commission

Deutsches Aktieninstitut welcomes the EU Commission's initiative to take stock of the current regulatory framework of banks. Non-financial companies among our members need both a strong European capital market as envisaged with the Savings and Investments Union and a strong, competitive European banking sector that can continue to provide financial services at sufficient scale and at affordable prices.

We welcome the EC´s report on the competitiveness of the EU banking sector as an important step towards a more efficient, proportionate and growth-oriented regulatory framework. The report rightly recognizes that financial stability and competitiveness are complementary objectives and provides a solid basis for strengthening the capacity of EU banks to finance investment, innovation and economic growth.

We welcome the Commissions intention to propose a regime allowing for a clearer identification of SNCI within the regulatory framework, irrespective of their legal and organisational structure. We also stress that, if properly understood, proportionality should be implemented taking into account business models serving the real economy, with a view to supporting broad-based and inclusive European growth.

The European FinTech Association (EFA) welcomes the Commissions Communication on the competitiveness of the banking sector and the single market in banking and appreciates the opportunity to provide feedback ahead of the 2027 legislative package. EFA represents FinTech companies and digital banks operating across the EU, many of which build crossborder, feebased business models.

The ABBL welcomes the European Commission ambition to strengthen the competitiveness of the EU banking sector and deepen the Single Market in Banking, while preserving resilience. The ABBL and its members highlight the following as key priorities: 1) Review the architecture of capital requirements The gradual accumulation of prudential requirements, buffers and backstops has resulted in an increasingly complex and…

PensionsEurope welcomes the opportunity to comment on the Communication on the competitiveness of the EU banking sector published on the 17 July 2026. PensionsEurope acknowledges the importance of building a more integrated, efficient, and competitive banking sector that can strengthen Europe's economy.

Arch welcomes the Commissions initiative to strengthen EU bank competitiveness while preserving resilience. As Commissioner Albuquerque stressed on 10 September 2026, banking competitiveness is a means of strengthening the European economy. The Commission Communication identifies three issues: fragmentation, insufficient recognition of EU specificities / proportionality, and undue regulatory complexity.

We welcome the initiative taken by the European Commission to assess and work on the competitiveness of the EU banking sector. We are especially supportive of section two of the Commission's Communication published on 17 June 2026 aiming to better consider European specificities and proportionality aspects when transposing global standards.

FECIF the European Federation of Financial Advisers and Financial Intermediaries welcomes the European Commissions Communication COM(2026) 615 of 17 July 2026 and its objective of strengthening the competitiveness of the EU banking sector and promoting a more integrated Single Market for financial services.

Banking regulation that no longer measures risk: the first Pillar 3 reports published in CRR III finally allow the output floor to be judged on its effects rather than on its intentions. What they reveal goes beyond the question of sizing: the mechanism is at odds with the principles that the Basel Committee had set for almost ten years.

Filed in French · English published by the European Commission

Aligning Action with Ambition The European Commissions Communication on the competitiveness of the EU banking sector (July 2026) is a welcome and urgent initiative to address the challenges facing the EU financial system and its economy.

Finance Denmark welcomes the European Commissions Report on the Competitiveness of the Banking Sector and the Single Market in Banking. The report provides an important basis for strengthening the competitiveness, integration and financing capacity of the European banking sector in support of Europes strategic objectives. Please find Finance Denmarks detailed response and recommendations in the attached submission.

European economys financing needs are expected to rise significantly in the coming years, exceeding 1.2 trillion per year, notably to support the energy transition, defence and digitilisation. It has become even more obvious that public funding cannot bridge this gap alone.

EuropeanIssuers welcomes the Communications recognition that banks and capital markets are inter-dependent and should develop in parallel, and strongly supports the Savings and Investments Union agenda. In particular, EuropeanIssuers considers that competitive European banks are essential to complement strong capital markets and ensure that European companies have access to the financing and services they need at…

A competitive EU banking sector is essential to delivering the Competitiveness Compass and Affordable Housing agenda, enabling banks to mobilise financing for households, businesses and the wider economy. -Completion of SIU: Completion of the SIU requires strong and complementary banking and capital markets.

ITFA’s reply to the Commission’s report on banking sector competitiveness in Europe The International Trade & Forfaiting Association (ITFA) welcomes the Commission's report as a positive and constructive step towards strengthening the competitiveness of the European banking sector and improving the ability of banks to support the European economy.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Nordic Financial Unions (NFU) supports the European Commissions ambition to strengthen the competitiveness of EU banking but argues that competitiveness should not be measured by scale and consolidation alone. A competitive banking sector also requires resilience, customer access, effective competition, skilled employees and strong operational capabilities.

Crédit Agricole Group welcomes the opportunity to contribute to the Commissions call for feedback on its Communication on competitiveness in the Single Banking Market. The EU banking sector has significantly strengthened its resilience.

"The German Savings Banks Association welcomes the European Commissions initiative to strengthen the competitiveness of the European banking sector and the Single Market and to review the supervisory and regulatory framework. Europe needs to finance substantial investment in the green and digital transformation as well as in strengthening its geopolitical resilience.

UK Finance welcomes the opportunity to respond to the European Commission Communication on the Competitiveness of the Banking Sector and the Single Market in Banking. Given the close and interconnected nature of the UK-EU financial services relationship, we think it is important that the Commissions proposals fully reflect the role that open, well-regulated and mutually supportive financial markets play in…

The Institute of International Finance (IIF) welcomes the Communication as an important milestone in moving from analysis to action. IIF members share the Commission's objectives and welcome its recognition that resilience and competitiveness are mutually reinforcing, and that resilience alone is not sufficient to support investment and growth.

Deutsche Börse Group supports the European Commissions focus on enhancing the competitiveness of the EU banking sector and capital markets. A robust, efficient, and integrated financial sector is essential to fund the green and digital transitions, support European businesses, and strengthen the EUs strategic autonomy.

WWF considers that the competitiveness of the EU banking sector should be assessed not only by banks profitability or market position, but by their ability to support a productive, resilient and sustainable European economy. Financial stability is a precondition for competitiveness.

As a feedback to the European Commission communication on banking sector competitiveness, the Association française des sociétés financières (ASF) would like to underline that specialised finance services are an industry of excellence in Europe, with large groups, regulated and supervised under CRR/CRD, operating across Europe in leading sectors such as leasing and factoring.

ShareAction has published a position paper on the competitiveness of the EU banking sector, which directly responds to this request for feedback on "Competitiveness in the single banking market". You can find it attached. A summary is below.

This opinion of the European Financial Congress has been prepared in response to the invitation to provide feedback on the document Competitiveness of the Banking Sector and the Single Market in Banking, published on 17 July 2026.

We welcome the Commissions report aimed at improving the competitiveness of the European banking sector. We support its effort to: Evaluate the regulatory treatment of strategic investments through specialised lending, including project finance for infrastructures and the energy transition, as well as the regulatory treatment of trade finance with a view to ensuring that European banks can support European companies…

ZIA broadly supports the faithful transposition of Basel III standards, but the current calibration generates structural constraints on real estate finance that are neither risk-proportionate nor aligned with the Union's housing and climate objectives.

The International Credit Insurance and surety Association (ICISA) welcomes the Commissions report aimed at improving the competitiveness of the European banking sector. ICISA is the global trade association for trade credit insurers, sureties, and their reinsurers.

The Malta Bankers' Association (MBA) welcomes the opportunity to comment on the EU Commission Report but our feedback emphasises particular issues arising from developments in cross-border digital banking, supervisory accountability and consumer protection. Our feedback is attached herewith in the PDF file; MBA comments re EU Commission Report - revised

Insurance Europes Perspectives IE welcomes the EC work on competitiveness and simplif, in particular the recently published Communication on the competitiveness of the EU banking sector. We welcome its recognition that a proportionate and coherent regulatory and supervisory framework is essential to support EU competitiveness and growth, while preserving financial stability and policyholder protection.

We appreciate that the Commission understands the importance of competitiveness and proportionality for the European banking industry and acknowledges the room for improvement in many areas. Regarding the Commission's proposals, we highlight the following concerns (also see our attachment for further details): A dedicated and proportionate regulatory framework is needed for non-systemic institutions with low-risk…

ESBG welcomes the European Commissions Communication on the competitiveness of the EU banking sector and the single market in banking. The Communication rightly recognises that a competitive banking sector is essential to finance growth, innovation and strategic priorities, while preserving resilience and financial stability. ESBG supports this balanced and forward-looking approach.

Accountancy Europe welcomes European Commission (EC) Communication on the competitiveness of the EU banking sector and the Single Market in banking. The Communication rightly recognises the need to simplify the regulatory framework while preserving the resilience and stability that Europe's banking system has built over the past decade.

We welcome that the Commission recognises the central role of the banking sector for the European economy and the need for reform in the regulatory framework. The Communication sends an important signal in favour of greater competitiveness and proportionality. The Commission has thoroughly analysed obstacles to the competitiveness of the EU banking sector and identified many important levers.

The Bank Policy Institute welcomes the European Commission's Communication of 17 July 2026 on the Competitiveness of the Banking Sector and the Single Market in Banking, and the opportunity to offer follow-up comments as the Commission prepares its Q1 2027 legislative package. This letter follows on from our more fulsome response of 19 April 2026 to the targeted consultation which is linked below.

Finansforbundet welcomes the Commissions Communication on the competitiveness of the EU banking sector. A competitive, resilient and diverse banking sector is essential for financing growth and investment in Europe and for providing high-quality financial services. Finansforbundet supports simpler regulation and reducing unnecessary administrative burdens.

As ABN AMRO Clearing Bank (AACB), one of the largest global General Clearing Members providing clearing and related services on all major exchanges and central counterparties across the world, we believe that enhancing competitiveness of the EU banking sector and establishing an efficient and resilient financial system is critical to a strong Union.

We welcome that the Communication of the EC (COM/2026/615 final) explicitly recognises the need to strengthen competitiveness while preserving and supporting the diverse structures of banking across the EU. In this context, it is essential that the regulatory and supervisory framework continues to acknowledge the specific role of all legal forms, including cooperatives and savings banks, where decentralised…

CONSULTATION RESPONSE September 16, 2026 Ref. COM(2026)615 Danske Bank Consultation Response on Competitiveness in the Single Banking Market 1. General remarks Danske Bank strongly welcomes the European Commission's report on the competitiveness of the EU banking sector.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Simplifying the EU Bank Capital Framework: A Start-from-scratch Test, and What APRA Can Teach Us To: European Commission (DG FISMA) From: Martien Lubberink Date: 30 August 2026 Re: A design test for the 2027 banking package, drawing on the Australian (APRA) framework Summary EU banks are now strongly capitalised, a point the Commission itself makes in its July 2026 competitiveness communication (European Commission…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

We welcome the Commissions report aimed at improving the competitiveness of the European banking sector. We support its effort to: Evaluate the regulatory treatment of strategic investments through specialised lending, including project finance for infrastructures and the energy transition, as well as the regulatory treatment of trade finance with a view to ensuring that European banks can support European companies…

We welcome the Communication, as it correctly identifies weaknesses in the existing regulatory framework. However, the Communication remains relatively general in outlining problem areas and possible courses of action and thus falls short of developing the concrete solutions that would have been desirable. To achieve tangible improvements within a reasonable timeframe, we advocate a two-stage legislative approach.

The Association of German Public Banks (Bundesverband Öffentlicher Banken Deutschlands, VÖB) welcomes the opportunity to contribute to the European Commission's Have Your Say-procedure on its Communication on the Competitiveness of the Banking Sector and the Single Market in Banking, published on 17 July 2026.

The Dutch Banking Association welcomes the European Commissions ambition to strengthen the competitiveness of the EU banking sector and deepen the Single Market in Banking, while preserving resilience. These objectives are urgent: Europe must mobilise substantial private and public investment for the twin transitions, to maintain strategic autonomy and to promote a more competitive economy.

We would like to highlight the following points: 1. Non-financial reporting outside the scope of CSRD The Omnibus directive (Directive (EU) 2026/470 of the European Parliament and of the Council of 24 February 2026), and the delegated act establishing sustainability reporting standards for voluntary use by undertakings protected by the value chain cap, ensure that enterprises subject to the CSRD cannot require…

Romanian Association of Banks supports the Commission's competitiveness agenda and believes that future reforms should focus on practical measures that deliver tangible benefits for the European economy. Priority should be given to reducing reporting burdens, enabling more efficient capital and liquidity management, simplifying the interaction between MREL and capital requirements, and reducing fragmentation arising…

Anasf welcomes Communication COM(2026) 615 of 17 July 2026, in which the European Commission sets out the initiatives needed to strengthen the competitiveness of the banking sector and to promote a more integrated single banking market.

Allianz supports the objective of creating a more integrated, resilient and competitive European financial system as outlined in the Commissions Communication on the competitiveness of the EU banking sector. Competitiveness should be pursued in a manner consistent with prudential soundness, fair competition and the principle of same activity, same risk, same regulation.

Polish Bank Association welcomes the opportunity to provide comments on the European Commissions Communication Competitiveness of the Banking Sector and the Single Market in Banking of 17th July 2026. Detailed comments attached.

The Savings and Investments Union initiative aims to assess how the EU banking sector contributes to increasing the competitiveness of the EU economy and to identify actions to address competitiveness issues, in particular structural barriers limiting cross-border activity and the integration of financial markets.

Filed in Italian · English published by the European Commission

Removing the barriers to financing Europe‘s economy Response to the European Commission‘s Communication on the Competitiveness of the EU Banking Sector — and priorities for the Q1 2027 banking package it will shape. A set of position papers, organised around four objectives.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Société Générale welcomes the European Commission’s communication on the competitiveness of the banking sector and the single banking market. In a European economy facing massive investment needs related to the energy transition, digital transformation, defence and economic sovereignty, the ability of banks to finance households and businesses is a strategic challenge.

Filed in French · English published by the European Commission

EAPB supports the Communications overall ambition: a simpler, more proportionate and more competitive banking framework that continues to safeguard resilience. 1. What EAPB welcomes Proportionality as a core objective.

The FEBEA Advocacy Lab welcomes the European Commissions communication on the competitiveness of the EU banking sector. The communication comes at a pivotal moment, as Europe must ensure its financial system continues to effectively support the green transition, finance social investments, as well as remain resilient to financial and climate-related shocks.

The Loan Market Association (LMA) very much welcomes the European Commission's focus on strengthening the competitiveness of the EU banking sector and its recognition that resilient and competitive banks play a central role in financing investment, innovation, and economic growth. For 30 years, the LMA has supported the loan markets, with a focus on enhancing liquidity, transparency, and sustainability.

Invito a presentare contributi della Commissione europea sulla Competitività del settore bancario e del mercato unico bancario 14 settembre 2026 Confcommercio accoglie con favore l'iniziativa della Commissione europea volta a rafforzare la competitività, la resilienza e l'integrazione del sistema bancario dell'Unione.

Filed in Italian · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Finance Sweden welcomes the Commissions initiative to strengthen the competitiveness of the EU banking sector and the single market in banking. A resilient, diverse and well-integrated banking sector is essential for financing the European economy.

Narodowy Bank Polski (the NBP) generally agrees with the objectives pointed out in the Commissions Communication aimed at enhancing the competitiveness of the banking sector in the EU. NBP shares the view that banks will continue to be essential founding source for the European economy. In this context, reducing any unnecessary burdens on banks deserves broad support.

The Association of Bavarian Cooperatives (Genossenschaftsverband Bayern e.V.) welcomes the European Commission's (EC) intention to review European banking regulation. Bank lending remains the primary source of financing for SMEs. Therefore, a strong and efficient banking sector is a key prerequisite for economic growth within the EU.

The European Commissions Communication on the competitiveness of the EU banking sector is a timely and welcome initiative. CaixaBank broadly agrees with the Commissions diagnosis, as it correctly identifies several long-standing challenges, including regulatory complexity, excessive reporting requirements, market fragmentation and obstacles that limit the banking sectors ability to finance the European economy…

Have your say SEB priorities Introduction Banks are at the heart of Europes economy. SEB supports the initiative to develop a deeper and broader European capital market and for this to materialise, Europes banks need the right environment to grow, compete, and consolidate.

Please see the attached IACPM Response to the Have Your Say on EU Bank Competitiveness. Our prior Response Letter to the EU Bank Competitiveness Consultation can be found here: https://iacpm.org/wp-content/uploads/2026/04/EU-banking-sector-competitiveness-IACPM-inputs-on-section-1-Credit-Risk-Sharing-and-Capital-Release-Final.pdf

Competitiveness is an important condition for stable and long-term growth of any banking sector. Therefore, Bank Guarantee Fund welcomes the European Commission (EC) Communication and supports further works aimed at simplifying the EU legal framework for the banking sector and creating the well-balanced EU regulatory environment for banks development.

We recommend that the Commission include trusted trade-finance interoperability and verified trade events among the thematic priorities for EU research and innovation funding from 2028 onwards. Cross-border trade increasingly generates authoritative digital evidence on shipment, delivery, customs, documentary and commercial events, but these data remain insufficiently connected to regulated financial processes.

The reports focus on REDUCING REPORTING BURDEN is very welcome. Replacing reporting with confidential data-sharing (following the example of the Central Bank of Brazil) would consist in a major burden reduction, enhancing competitiveness, especially when supervisors in turn share aggregate measures of the data with the industry, together with insights from their macro-level assessments.

The reports focus on REDUCING REPORTING BURDEN is very welcome. Replacing reporting with confidential data-sharing (following the example of the Central Bank of Brazil) would consist in a major burden reduction, enhancing competitiveness, especially when supervisors in turn share aggregate measures of the data with the industry, together with insights from their macro-level assessments.

UNI Europa Finance welcomes the Commission's report on the competitiveness of the EU banking sector, but is concerned that it does not reflect the input of Europe's 1.5 million finance sector workers, provided through our April 2026 consultation reply and that of other trade unions.

A more competitive Europe, which delivers, inter alia, on the green and digital transitions, strengthens energy security, and enhances defence capabilities, requires more competitive European banks. This heavily depends on embracing three guiding principles: first, Europe needs more harmonized regulation and less national fragmentation, reducing gold-plating and removing national measures that unnecessarily restrict…

The World Federation of Exchanges (WFE) position in response to the European Commission's consultation on its Communication on the Competitiveness of the Banking Sector and the Single Market in Banking, published on 17 July 2026, is set out in the attached document.

The Czech National Bank's (CNB) position in response to the European Commission's consultation on its Communication on the Competitiveness of the Banking Sector and the Single Market in Banking, published on 17 July 2026, is set out in the attached document.

The Communication rightly identifies the need to strengthen the competitiveness of the European banking sector. From an Artificial Intelligence (AI) perspective, competitiveness should not be measured solely by the speed of technological adoption, but by the institutional capacity to deploy AI while preserving supervisory confidence, legal certainty, operational resilience and customer trust.

The Bank welcomes the European Commissions initiative to assess the competitiveness of the EU banking sector and recognises the important role that banks play in supporting economic growth, investment and financial stability across the European Union.

Banco Santander welcomes the European Commissions Communication on the competitiveness of the banking sector and the Single Market in banking. It provides a useful foundation for strengthening Europes banking sector while safeguarding financial stability. We particularly welcome the Commissions call for a more proportionate, risk-based and economically grounded approach to regulation and supervision.

The French Banking Federation (FBF) welcomes the European Commission's recognition that prudential rules should be assessed not only through the lens of financial stability, but also through their impact on growth, investment and financing capacity.

As the voice of the Spanish Savings and Retail Banks, CECA represents 43% of the Spanish market mortgages; 35% of its retail credit; 38% of its retail deposit and more than 1 billion euros invested in social activities.

The proposed initiative on the competitiveness in the single banking market is largely influenced by the idea that lower capital requirements and prudential obligations would increase bank competitiveness and - in turn - benefit the EU economy. Yet, research shows that there is no evidence that higher capital buffers lead to structural restrictions on lending.

The discussion about competitiveness of the banking sector needs to focus on the long term sustainability-linked resilience of EU banking sector as a whole in order to finance the long term and sustainable transformation of the EU economy and households.

For this Call for Evidence, we attach a document with sources and evidence that Finance Watch has found relevant to the Commissions initiative. Finance Watch encourages the Commission to use this initiative to tidy up banking regulation in ways that promote capital strength, system resilience and lending to productive economic activities.

We welcome the European Commissions initiative to review the EU banking framework in a holistic manner and its objective to enhance competitiveness while safeguarding financial stability. In particular, we support ongoing efforts to simplify and streamline the regulatory framework.

The EACB welcomes the call for evidence on Competitiveness in the single banking market. This is a much needed step in the context of the roader efforts by the European Commission around simplification and competitiveness undertaken since 2025.

For a more elaborate description of the Sustainable Finance Labs argument please see the attached policy brief. A competitive EU banking sector should be defined by its ability to absorb shocks while continuing to finance households and businesses, as much as it should be defined by profitability or market share. Adequate prudential policy by both financial institutions as well as supervisors is fundamental to this.

We welcome the opportunity to provide feedback on the European Commission Call for Evidence on Competitiveness in the single banking market. As an insurance company with significant holdings in the banking sector, we support the Commission's initiative to strengthen the competitiveness of the EU banking market.

The German Savings Banks Association (DSGV) welcomes the European Commissions Call for Evidence on the competitiveness of the Single Banking Market. In our view, the competitiveness of the EU banking sector should be assessed not only by reference to size, cross-border consolidation or capital market footprint, but also by banks ability to finance households, SMEs, municipalities and long-term transformation needs…

First, impressions of what constitutes and promotes bank competitiveness should be carefully reconsidered. Research on historical credit guidance policies shows that many advanced European economies steered bank lending toward productive sectors from the post-war period until the 1980s, ensuring bank credit supported investment and economic growth.

Build Europe represents the European residential development and homebuilding sector, whose members rely largely on bank financing for the acquisition, development and construction of new housing. The full feedback and the supporting annexes are attached to this submission.

The European factoring industry plays a central role in financing the real economy, providing more than 2 trillion in annual liquidity and supporting over 300,000 businesses across the EU. With 3.9 trillion in global turnover, two thirds generated in Europe, factoring constitutes a core financial infrastructure that ensures stable working capital funding, strengthens payment discipline, and enhances supply chain…

The European Financial Regulation Circle, a think-tank made up of risk management and regulatory experts, welcomes the mandate given by the Member States to the European Commission to produce a report on the competitiveness of European banks.

Filed in French · English published by the European Commission

Mortgage lending represents nearly 9 trillion in outstanding loans , close to 50% of EU GDP, and remains the primary source of financing for homeownership in Europe. By enabling affordable and sustainable homeownership, mortgage markets improve social conditions and provide stability at the household level. They encourage investment and foster job creation and are major drivers of the EU economy.

The European banking sector has become significantly more resilient over the past decade. Discussions on competitiveness often focus narrowly on profitability indicators, yet the performance of banks should primarily be assessed based on their ability to support financial stability and provide financing to the real economy.

The European banking sector plays a central role in financing Europes strategic priorities, from innovation and sustainability to defence and digital transformation. As Europes economy remains predominantly bank-financed, banks are not only enablers but key drivers of Europes competitiveness and strategic autonomy.

A key competitiveness issue is whether the EU prudential framework remains coherent and proportionate across Member States, or whether cumulative requirements create uneven effects that undermine investment capacity.

A strong focus on competitiveness and level playing field is needed for banks to be able to finance the EUs strategic goals and to enable European banks to compete internationally. Main recommendations for level playing field in banking regulation are 1.

Executive Summary: European banking competitiveness is increasingly constrained by the EUs implementation of Basel 3.1 and a fragmented macroprudential framework. The Basel 3.1 Output Floor is set to become a binding capital requirement for most European IRB banksunlike in other major jurisdictionsthereby raising financing costs and reducing lending capacity.

Executive Summary The attached paper challenges the framing that regulatory complexity and capital requirements are the primary obstacles to EU banking competitiveness. Drawing on recent research, we argue that complexity stems from financial innovation and from internal models used by banks in order to reduce effective capital requirements.

The attached European Banking Institute (EBI)s Report on the Simplification of EU Financial Law (January 2026) is the result of a collective endeavour among members of the Academic Board of the EBI. It seeks to clarify what simplification should be and how simplification efforts could be structured in a manner that remains institutionally and methodologically robust particularly in light of the Savings and…

The Association of German Pfandbrief Banks (vdp) welcomes the European Commissions review of EU banking competitiveness, emphasising that regulation has become a key factor in competitiveness. Although post-crisis reforms have strengthened resilience, the increasingly complex regulatory landscape, characterised by overlapping responsibilities, expanding supervisory expectations and high operational burdens, has…

This submission by the Leibniz Institute for Financial Research SAFE provides evidence based on the paper prepared for the ECON Committee of the European Parliament in April 2025 on the question of How have European banks developed along different dimensions of international competitiveness?.

LAfep, the Voice of large French companies, brings together 117 companies representing 4 million employees in Europe, 8 million worldwide, and 70% of the market capitalization of the French stock exchange. LAfep Members are committed to transitioning their business models to reduce their emissions and, in the future, will face huge investments to finance their activities, their transitions and remain competitive.

From a product development perspective, our contribution to the EUs Savings and Investment Union (SIU) can be framed within the broader context of the structural and competitiveness challenges. However, a more critical assessment is required as to whether the cumulative layering of prudential and supervisory requirements has reinforced fragmentation rather than alleviating it.

The Savings and Investments Union initiative aims to assess how the EU banking sector contributes to increasing the competitiveness of the EU economy and to identify actions to address competitiveness issues, in particular structural barriers limiting cross-border activity and the integration of financial markets.

Filed in Italian · English published by the European Commission

The EU banking sector's persistent underperformance relative to international peers, reflected in a decade-long market-to-book ratio below 1.0, is fundamentally a problem of structural fragmentation, not of over-regulation. This distinction is central to our submission.

The Central Association of German Crafts (ZDH) represents the interests of 1 million craft businesses employing around 5.6 million people. These businesses would also benefit from the simplification of banking regulation, which could facilitate lending. In particular, proportionate requirements are needed for small banks as well as for lending to small businesses.

Filed in German · English published by the European Commission

Please find attached our response to the Call for Evidence on competitiveness in the single banking market. The position paper outlines our key priorities for regulatory relief and sets out a number of concrete proposals to enhance the competitiveness of the EU banking sector.

We write as representatives of the European corporate treasury community, actors responsible for financing, liquidity, and risk management in companies across sectors and jurisdictions. Our ability to support investment, employment and competitive growth depends on having available and reliable choice among financing and hedging partners.

The Association française des sociétés financières (ASF) is representing the specialized financing institutions which activities contribute to financing projects undertaken by companies and professionals through specific products such as leasing, both equipment and real estate.

(complete position paper attached) PBA welcomes the opportunity to present comments in this consultation. The banking sector plays the dominant role on the EU financial market and it is the most important source of financing for economy and households. We need the banking sector well diversified.

We applaud the Commissions initiative to develop a Communication on the Single Market in banking, particularly its commitment to deepening the Savings and Investments Union (SIU) and boosting Europes global competitiveness.

European banks are resilient and form a core pillar of Europe strategic autonomy. Yet the post 2008 regulatory framework, continually expanded over the years, has become structurally restrictive. Layers of capital immobilisation and cumulative supervisory add ons significantly reduce banks financing capacity at a time when Europe faces Euros 800 billion in annual investment needs.

The Savings and Investments Union initiative aims to assess how the EU banking sector contributes to increasing the competitiveness of the EU economy and to identify actions to address competitiveness issues, in particular structural barriers limiting cross-border activity and the integration of financial markets.

Filed in Italian · English published by the European Commission

Reclaim Finance warns the Commission against calls to lower the regulatory requirements on the banking sector. Indeed, some EU banks and their representative bodies use the current focus on competitiveness and simplification to demand lower regulatory obligations, including reduced capital requirements. Yet, as the enclosed note summarizes, the arguments used to justify these demands are often misleading.