AFME

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.

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.

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) 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) 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.