AFME

Ahead of the publication of the Digital Omnibus package, we wanted to reiterate our support for the Commissions drive on Simplification, which has the potential to streamline the regulatory burden on industry and boost EU competitiveness.

2022-03-31 Pág. 1 de 22 Proposed amendments to EPBD recast proposal Electrical Installations Electrical installation as TBS Amendment Proposal for a directive Article 2 Definitions Text proposed by the Commission Amendment 6.

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

AFME Recommendations on European Commission Draft Revised ESRS 3 June 2026 The review of the ESRS is a critical element of the Commission’s Sustainability Omnibus initiative and a vital lever for delivering simplification. AFME strongly supports the orientations set out by the Commission for the revision of the ESRS, which co-legislators have endorsed in the final Omnibus I text.

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

Association for Financial Markets in Europe Consultation Response Inception Impact Assessment - Proposal for a Legal Act of the European Parliament and the Council Laying Down Requirements for Artificial Intelligence 10 September 2020 The Association for Financial Markets in Europe (AFME) welcomes the opportunity to comment on INCEPTION IMPACT ASSESSMENT - PROPOSAL FOR A LEGAL ACT OF THE EUROPEAN PARLIAMENT AND THE…

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

The Association for Financial Markets in Europe (AFME) and the International Swaps and Derivatives Association (ISDA) welcome the opportunity to respond to the European Commissions public consultation on the EU Emissions Trading System (EU ETS) for maritime, aviation and stationary installations, and on the Market Stability Reserve (MSR).

The Association for Financial Markets in Europe (AFME) and the International Swaps and Derivatives Association (ISDA) (together, the Associations) welcome the European Commissions proposed revision to the Sustainable Finance Disclosure Regulation (SFDR 2.0). The proposal represents important progress towards achieving the original policy objectives of the SFDR.

The Association for Financial Markets in Europe (AFME) is the voice of all Europe’s wholesale financial markets, providing expertise across a broad range of regulatory and capital markets issues. We represent the leading global and European banks and other significant capital market players.

The Association for Financial Markets in Europe (AFME) is the voice of all Europe’s wholesale financial markets, providing expertise across a broad range of regulatory and capital markets issues. We represent the leading global and European banks and other significant capital market players.

The Association for Financial Markets in Europe (AFME) welcomes the opportunity to comment on the European Commission’s proposal for a Regulation on European Data Governance (Data Governance Act). AFME represents a broad array of European and global participants in the wholesale financial markets.

The Association for Financial Markets in Europe (AFME) welcomes the opportunity to comment on the European Commission's Inception Impact Assessment (referred to hereafter as the “Assessment”) on a Legislative Framework for the governance of common European Data Spaces. AFME represents a broad array of European and global participants in the wholesale financial markets.

The Association for Financial Markets in Europe (AFME) and the International Swaps and Derivatives Association (ISDA) believe that the European Commission’s proposal for a Corporate Sustainability Reporting Directive represents an important step towards improving the quality and availability of sustainability information.

2025-07-16 Pág. 1 de 3 Response to the Public Consulta on on the Revision of Regula on (EU) No 1025/2012 on European Standardisa on AFME, the Spanish associa on represen ng manufacturers of electrical installa on equipment, welcomes the opportunity to contribute to the public consulta on on the revision of Regula on (EU) No 1025/2012 on European standardisa on. 1.

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

Please find attached the response from AFME, representing the views of the globally significant credit institutions. We would be happy to discuss further our comments, particularly those relating to the Mobile Banking Application, where we welcome the recent engagement with industry, and the clarity on specific functions, but think the references to API architecture need adjusted.

In our Digital Omnibus Call for Evidence, AFME highlighted the need for a sectoral exemption from the Cyber Resilience Act, in light of the level of overlap with DORA. As a general overarching rule, it is vital that horizontal initiatives respect the primacy of sectoral legislation already in operation.

In the set of recommendations attached to this submission, AFME outlines our detailed views on the European Commissions Retail Investment Strategy proposals for the Omnibus Directive amending, among others, the Markets in Financial Instrument Directive (MiFID) and the Regulation amending the Regulation on key information documents for packaged retail and insurance-based investment products (PRIIPs).

1. AFME responded to the European Commission’s EU Strategy for Retail Investors consultation on 3rd August 2021. Inducements and quality of advice AFME members are not supportive of establishing an outright ban on inducements.

2025-08-27 1/3 Response to the Public Consulta on on Omnibus Direc ve and Regula on Aligning product legisla on with the digital age. AFME, the Spanish associa on represen ng manufacturers of electrical installa on equipment, welcomes the opportunity to contribute to the public consulta on on Omnibus Direc ve and Regula on aligning product legisla on with the digital age.

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

The Association for Financial Markets in Europe (AFME) welcomes the opportunity to respond to the European Commissions call for evidence on the forthcoming Omnibus on Taxation. Further details are provided in our attached feedback, including a joint contribution with ISLA and ISDA, which highlights the need for greater harmonisation and simplification with respect to the meaning and application of beneficial…

AFME welcomes the opportunity to give feedback on the Market Integration and Supervision Package (MISP). Our detailed position paper is attached. AFME believes that this package is a pivotal step toward strengthening competition across the entire capital markets ecosystem, increasing investor choice, improving market efficiency, and mobilising capital at scale to support long-term growth.

2025-08-27 1/3 Response to the Public Consulta on on Omnibus Direc ve and Regula on Aligning product legisla on with the digital age. AFME, the Spanish associa on represen ng manufacturers of electrical installa on equipment, welcomes the opportunity to contribute to the public consulta on on Omnibus Direc ve and Regula on aligning product legisla on with the digital age.

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

The Association for Financial Markets in Europe (AFME) believes that the EUs proposed Financial Data Access (FiDA) framework and Payments Services Regulation (PSR), if designed correctly, have the potential to enhance the way banks operate, encourage innovation, and support a more effective and efficient data ecosystem and payments system.

AFMEs preliminary feedback aims to support the proposals objective to introduce transparency and governance requirements for ESG ratings providers aligned with the IOSCO recommendations. We highlight, from the perspective of bank and asset manager members as users, rated entities and regulated financial undertakings, that the scope of the proposal should not unintentionally capture products or activities of…

The Association for Financial Markets in Europe (AFME) welcomes the opportunity to comment on the European Commissions Proposal for a Council Directive on Faster and Safer Relief of Excess Withholding Taxes (FASTER). AFME strongly supports the Commissions objectives to simplify and digitise withholding tax processes within the EU.

The Association for Financial Markets in Europe (AFME) welcomes the opportunity to provide its feedback to the European Commission on the “New EU system for the avoidance of double taxation and prevention of tax abuse in the field of withholding taxes”. Our comments on the Inception Impact Assessment have been submitted via a separate document. We would be pleased to assist with this initiative.

AFME welcomes the opportunity to provide comments on the European Commission Standard Contractual Clauses (SCCs) for transferring personal data to non-EU countries. Businesses from the financial services sector of all sizes rely on SCCs for data transfers that are essential to their activities.

AFME welcomes that the European Commission proposes that Mandatory Buy-ins (MBI) will not be immediately implemented. As acknowledged in the Commission’s impact assessment, the implementation of a MBI Regime could have a disproportionately negative impact on the liquidity and competitiveness of EU capital markets.

Settlement Discipline Framework AFME believes that changes to the Settlement Discipline Regime (“SDR”) should be considered the key priority of the CSDR Refit. Although the rules have not yet entered into force, there are fundamental issues with their current form. The CSDR Refit presents a perfect opportunity to make targeted amendments to the SDR to ensure its effectiveness from day one.

The Association for Financial Markets in Europe (AFME) welcomes the opportunity to comment on the European Commission’s proposal laying down rules to prevent the misuse of shell entities for tax purposes (ATAD 3). AFME welcomes the Commission’s plans to crackdown on tax avoidance and evasion to ensure fair and effective taxation and preserve the integrity of the internal market.

AFME supports the objectives of the European Commission’s Capital Markets Recovery Package as part of the Commission's overall COVID-19 recovery strategy and welcomes the opportunity to comment on the targeted adjustments to the MiFID II research unbundling regime set out in the draft delegated act. AFME’s response to the consultation can be found attached.

The Association for Financial Markets in Europe (AFME) is pleased to provide feedback on the European Commission’s roadmap on the upcoming initiative fora new comprehensive approach to preventing and combating money laundering and terrorism financing .

The Association for Financial Markets in Europe (AFME) welcomes the opportunity to respond to the EU proposal to amend the Directive on administrative cooperation in the field of taxation (DAC) to include crypto assets and amend the Common Reporting Standard (CRS) to include electronic money products and central bank digital currencies (the Proposal).

The Association for Financial Markets in Europe (AFME) welcomes the opportunity to comment on the European Commission’s legislative proposals for an EU regulatory framework for crypto-assets. AFME represents a broad array of European and global participants in the wholesale financial markets.

The Association for Financial Markets in Europe (AFME) welcomes the opportunity to comment on the European Commissions call for feedback on targeted amendments to the Liquidity Coverage Ratio Delegated Regulation. Please find our feedback in the uploaded file.

AFME and its members have noted the European Commissions Call for Evidence for an initiative in relation to the treatment of reverse repos and unsecured lending under the NSFR standard. The industry considers it essential that an initiative is issued from the European Commission to extend permanently the application of the current 0%, 5% and 10% RSF factors for reverse repos secured by Level 1 HQLA and non-Level 1…

The Association for Financial Markets in Europe (AFME) supports the European Commission’s proposal for a ‘Regulation on Digital Operational Resilience in the Financial Sector’ (DORA). To support the Commission's proposal we have summarised our key considerations: - A risk-based approach should be adopted that aligns with the existing EBA Guidelines on ICT and Security Risk Management and Guidelines on Outsourcing…

The Association for Financial Markets in Europe (AFME) welcomes the European Commissions proposed Settlement Finality Regulation (SFR), which modernises the existing Settlement Finality Directive to accommodate distributed ledger technology (DLT) and other emerging technologies while preserving critical protections for transfer orders, netting, and collateral.

AFME is scratch for the opportunity to respond to the European Commission’s Roadmap for an EU strategy for retail investors. AFME welcome the European Commission’s planning towards a comprehensive strategy for retail investors, building on the CMU HLEF report of June 2020.

Filed in French · English published by the European Commission