ANASF

The revision of the SFDR Regulation represents a crucial moment for the evolution of sustainable finance in Europe. Anasf the National Association of Financial Advisors in Italy has expressed proactive positions in the context of the European debate, highlighting both operational criticalities and areas for regulatory improvement.

ANASF agrees with the general aim of this proposal, i.e. the integration of ESG in disclosures to end-investors. In particular, we appreciate the integration of sustainability risks and sustainable investment objectives both in the decision-making processes by institutional investors and asset managers and in the advisory processes by financial advisors.

We agree with the proposal aimed at amending the delegated act under MiFID II to ensure that sustainability considerations are taken into account in the advisory process, both in the customer profiling and subsequent product selection.

We agree with the proposal aimed at amending the delegated act under IDD to ensure that sustainability considerations are taken into account in the advisory process, both in the customer profiling and subsequent product selection.

The targets of the proposed legislative act are acceptable. In particular, we agree on the broadening of the scope of application of corporate sustainability disclosure to include all big companies and listed companies (except for SMEs), the assurance requirement of sustainability disclosure, the more detailed definition of the information that companies should disclose.

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.

ANASF, Associazione nazionale consulenti finanziari, is the national association representing financial advisors authorised to offer investment services off the premises of financial intermediaries (consulenti finanziari abilitati allofferta fuori sede) registered in the official national register pursuant to Article 31 of the Consolidated Law on Finance (Legislative Decree no. 58/1998).

We agree that the problem of low financial literacy is relevant and that targeted financial education initiatives are needed, as is the education activity carried out by financial advisor to clients. The PRIIP Regulation has improved the comprehension of investment products. An assessment of its effectiveness will only be possible when it will be effectively implemented.

We welcome the approach aimed at promoting greater regulatory uniformity in the European market through the transition from a directive to a regulation. This choice appears consistent with the objective of ensuring more effective harmonisation of regulated activities throughout the Union, reducing differences in interpretation and application between Member States.

We welcome the approach aimed at promoting greater regulatory uniformity in the European market through the transition from a directive to a regulation. This choice appears consistent with the objective of ensuring more effective harmonisation of regulated activities throughout the Union, reducing differences in interpretation and application between Member States.

ANASF welcomes the European Commission's initiative to develop rules that promote market integration and more efficient supervision. We believe that, in order to achieve this goal, it is essential to address the obstacles that still prevent a truly competitive and open capital market. The main obstacles faced by financial advisors are of a fiscal and legislative nature.

We are basically satisfied with the proposal for a regulation presented by the Commission. However, we consider it appropriate to specify in the Regulation, in a clear manner, that is permissible the compensation for data retention by the data holders, and that it is not instead permissible to provide for a compensation for the sale of customer data by the data holder to an end-user: customers data are in fact the…

Dear Commission, in accepting the invitation in the consultation paper on the Proposal for a regulation of the European Parliament and of the Council on amending Regulations (EU) No 260/2012 and (EU) 2021/1230 as regards instant credit transfers in euro, ANASF - National Association of Financial Advisors intends to express the following remarks.

Anasf shares the possibility, identified in recital 43 and in Article 16 of the European Commission’s proposal for a Directive, to provide advice in the form of personalised recommendations in combination with the granting or intermediation of credit, provided that it is clear to the consumer what the advice service consists of, precisely because of the importance of this service in other areas.

The proposal for a Regulation presented by the European Commission lays the foundations for a common framework of rules governing the bonds that follow environmental sustainability objectives in accordance with the provisions of Regulation (EU) 2019/2088 on taxonomy resolving, as pointed out by Anasf in the response to the Commission consultation last year, some of the problems that have negatively affected the EU…

Dear Commission, in accepting the invitation referred to in the consultation paper on the proposal for a Regulation of the European Parliament and of the Council amending Regulation (EU) 2015/760 as regards the scope of eligible assets and investments, the portfolio composition and diversification requirements, the borrowing of cash and other fund rules and as regards requirements pertaining to the authorisation…

Dear Commission, In responding to the invitation contained in the consultation document on the Proposal for a Directive of the European Parliament and of the Council amending Directives 2011/61/EU and 2009/65/EC as regards delegation arrangements, liquidity risk management, supervisory reporting, provision of depositary and custody services and loan origination by alternative investment funds, ANASF – Associazione…

Dear Commission, in accepting the invitation referred to in the consultation paper on the Proposal for a regulation of the European Parliament and of the Council on Markets in Crypto-assets, and amending Directive (EU) 2019/1937, ANASF - National Association of Financial Advisors intends to express the following remarks.

The fact that certain issues regarding PEPPs have been acknowledged is certainly a positive development; however, the proposal as a whole remains unsatisfactory. The product should be much more accessible, especially for young people and for workers who move frequently between different countries. Furthermore, significant concerns remain regarding the overall structure of the initiative.

Dear Commission, In responding to the invitation contained in the consultation document on the Proposal for a Directive of the European Parliament and of the Council amending Directive 2011/83/EU concerning financial services contracts concluded at a distance and repealing Directive 2002/65/EC, ANASF – Associazione Nazionale Consulenti Finanziari, representing over 12.000 Italian financial advisors, intends to…

The proposed revision of the IORP II and IDD directives is part of a process aimed at progressively strengthening European supervisory authorities, a move that nevertheless raises significant concerns. The transfer of powers from Member States to the European level risks upsetting the institutional balance and reducing the scope for national autonomy, with potential implications for democratic legitimacy as well.