Italian Banking Association

ABI supports the approach of the Delegated Act, relying on the EFRAG proposal, considered a balanced solution. We welcome the option to use the revised ESRS for FY 2026. To this end, to provide certainty to the market it is necessary that the DA is finalized in a timely manner.

Il documento rappresenta il contributo dell'Associazione Bancaria Italiana (ABI) al dibattito in tema di Intelligenza Artificiale ed è stato redatto con l'attivo contributo dei gruppi di lavoro composti dalle banche associate e da esperti in materia. Nel ringraziare per l'opportunità, rimaniamo a disposizione per ogni approfondimento. Con i migliori saluti, Silvia Attanasio

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.

Please find enclosed ABI’s remarks on the EUROPEAN COMMISSION on the Draft Delegated Regulation amending Regulation (EU) 2017/565 supplementing Directive 2014/65/EU as regards organisational requirements and operating conditions for investment firms and defined terms for the purposes of that Directive.

General comments The proposed Corporate Sustainability Reporting Directive (CSRD) is a central component of the sustainability reporting requirements underpinning the EU’s sustainable finance strategy, together with the Sustainable Finance Disclosure Regulation (SFDR) and the Taxonomy Regulation.

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.

ABI supports the creation of the CMU and its objectives, including that to facilitate retail investor participation in the EU capital market. The Retail Investment Strategy, however, proposes regulatory changes that would have a significant impact on the financial industry, adversely affecting the development of the EU capital market.

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.

The Italian Banking Association supports the objectives of the proposal for a regulation on a Framework for Financial Data Access (FIDA) as part of the European Digital Finance Strategy. The proposal takes into account some important concerns represented by the financial industry during the preliminary consultation held in 2021.

The Italian Banking Association (ABI) appreciates the opportunity to provide its feedback through the "Have your say" procedure, given the importance of the topic. We welcome the concept outlined in the proposal, where each Member State shall issue a European Digital Identity Wallet (EDIW) after the entry into force of this Regulation: Identity issuance will remain a Member State responsibility, as it is currently…

1. We agree on the desirability of a common, standardised EU-wide system of exemptions and reductions of withholding taxes on cross-border income flows. This would reduce the impact of double taxation and would be a significant improvement on the current situation where several procedures are still based on paper documents, resulting in the need to apply for different originals, with long lead times and inconsistent…

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).

ABI supports the establishment of a European Single Access Point as we believe that the proposals for a voluntary contribution scheme open to all companies, the public management of the initiative, entrusted to ESMA, and the free and widespread access to the information will contribute to proceed in the right direction.

In terms of entities subject to the settlement penalties, as we elaborated in our Response to the Commissions’ consultation on a Possible Review of the CSDR (run between December 2020 and February 2021), we continue to suggest the removal of CCPs’ responsibility on the collection and distribution of penalties to clearing members affected by the settlement fails, moving this responsibility on CSDs for both cleared…

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).

ABI supports the aim of the CMU Action Plan to foster the use of capital markets by European companies as well as the efforts to simplify the EU listing regulatory framework. An effective alleviation of the listing and the post-listing obligations is definitely needed, as well as a reduction of the costs for the issuers.

Multiple-vote share structures represent a mechanism to allow companies owners to retain decision-making powers in a company while raising funds on public markets and, thus, make the process of accessing the European capital markets by small enterprises and entrepreneurs more acceptable as the ownership structure is not diluted.

The investment research unbundling rule, early introduced under MIFID II and then amended by the CMRP, has not contributed to the growth and the improvement of investment research and, de facto, has not achieved at all the objectives they were originally designed to pursue.

ABI provides hereinafter first comments on the EU Green Bond Standard Proposal Regulation (EUGBS), adopted by the European Commission in July 2021, which introduces a common framework of rules governing green bond issuances in accordance with the provisions of Regulation (EU) 2019/2088 on Taxonomy.

Content of the proposal for a Regulation. The content of the proposal for a Regulation: (I) seems difficult to interpret; (II) focuses primarily on the role and activities of the European Commission; (III) provides for a procedure for the application of response measures by the EU which, in ABI’s view, appears to be too complex because of its length and the burdens it has at its disposal.

Filed in Italian · English published by the European Commission

The following provides a briefing on the main items of ABIs attached position paper. On the Active Account (AAC, Art.7a) we suggest clarifying and revising its scope of its application in terms of entities, contracts and phased-in implementation. As for entities, current scope refers to any FCs and NFCs regardless the presence of open positions at Third Country CCPs.

The proposal regarding paragraph 5 of Article 61 of the Directive 2011/61/EU contains an explicit derogation from the obligation in this regard provided for by Article 21 of the same Directive, but it has a generic wording and, as such, it allows for a broad application.

The Italian Banking Association would like to thank the European Commission for the opportunity to provide feedback on the proposed Regulation on a pilot regime for market infrastructures based on distributed ledger technology. Please see document attached.

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 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).

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.

ABI welcomes the Commissions effort to optimize the Crisis Management and Deposit Insurance framework by amending three legislative texts, namely the Banking Recovery and Resolution Directive (BRRD), the Single Resolution Mechanism regulation (SRMR) and the Deposit Guarantee Schemes Directive (DGSD).

Italian Banking Association (ABI) welcomes the Commissions effort to optimize the Crisis Management and Deposit Insurance framework by amending three legislative texts, namely the Banking Recovery and Resolution Directive (BRRD), the Single Resolution Mechanism regulation (SRMR) and the Deposit Guarantee Schemes Directive (DGSD).

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

We support the wide scope of financial instruments subject to consolidation but we do not favour the multiple-CTPs model (a CTP per Asset Class). In our view a single, public and institutional CTP would be more efficient for the final users in terms of number of data sources and overall cost for accessing consolidated data. As for the governance of CTPs, the Proposal foresees competitive privately-owned operators.

The Italian Banking Association welcomes the possibility of commenting on the Commission’s proposal for amendments to the so-called ‘Blocking Statute’, which have been put forward in order to curb the phenomenon of the consequences for EU countries of financial penalties adopted by third countries.

Filed in Italian · English published by the European Commission