ABI - Italian Banking Association

We agree with the importance of revising the current framework on sustainability-related disclosure in financial services (SFDR) in order to effectively simplify the current disclosure requirements and to address the various shortcomings with the interpretation and implementation of the current requirements.

We confirm the paramount importance to revise the Sustainable Finance Disclosure Regulation (SFDR) to effectively simplify the current disclosure requirements and to resolve the numerous issues in the interpretation and implementation of current requirements, as already represented in our response to the preliminary consultation in 2023.

The Italian Banking Association (hereinafter ABI) represents and promotes the interests of almost 600 Italian banks and financial intermediaries. ABI welcomes the opportunity to comment on the European Commission Call for Evidence on Omnibus on Taxation. Please find attached our suggestions aimed at ensuring that this initiative fosters an EU tax framework that supports the competitiveness of EU businesses.

We appreciate the opportunity to share our members views on the European Commissions Proposal for the MISP Regulation. Given the broad scope and variety of topics addressed, we have prepared the attached position paper commenting in detail the MISP Regulations proposal.

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.

We welcome the choice of a Regulation for the provisions on the scope of payment services (PSs), transparency and rights and obligations as it goes in the direction to create a uniform EU regulatory framework avoid fragmentation and competitive disparities. We agree that the proposals entail an evolution of the payment sector leveraging the investment already made (e.g.PSD2 dedicated interfaces).

The green mortgage loans - loans granted for the purchase of high-energy-performance properties or for the energy renovation of buildings - has recorded, in 2023, a significant increase in the Italian market (accounting for: (i) 10% of the total mortgages for the purpose of purchasing; (ii) 16% of those intended for the renovation and/or construction of a residential property).

We agree with the importance of revising the current framework of pan-European Personal Pension Product (PEPP) in order to make it more flexible and attractive and thus allowing a more dynamic market able to meet the individual needs of savers.

Securitisation can allow banks to strengthen and increase their capability to provide more lending to the real economy, enabling them to free up regulatory capital which can be used to originate new loans, and it can contribute to a well-diversifying funding source.

ABI (shared at European level EBF) strongly supports the European Commission proposal aimed at making permanent the current transitory prudential treatment for SFT and unsecured transactions with a residual maturity of less than six months, with financial customers, for the purpose of the Net Stable Funding Requirement (NSFR) (i.e. to extend the current treatment also beyond 28 June 2025, and permanently).

We appreciate the opportunity to share our members views on the European Commissions Proposal for a Regulation on Settlement Finality (SFR), repealing Directive 98/26/EC. The migration of the provisions from the current Directive to a forthcoming Regulation seems positive in the interests of harmonization in the EU thereby reducing legal uncertainty and enhancing predictability.

We agree with the importance of revising the current framework of occupational retirement provision in order to boost supplementary pensions by making it easier for people to access such pensions and strengthening the capacity of pension schemes (occupational pensions and personal pension plans) to invest efficiently and achieve better investment outcomes.

The Italian Banking Association considers that the European Commission’s review of the Notice on State aid in the form of guarantees is of particular relevance in the light of developments in the financial markets, the regulatory framework on State aid and the experience gained in applying it in recent years.

Filed in Italian · English published by the European Commission