The Austrian Raiffeisen Banking Group (RBG) basically appreciates the determination of the European Commission to increase the resilience of the EU banking sector by continuously implementing the Basel III framework in a step-by-step approach. However, we would like to raise the attention to specific elements of the EC's legislative proposal on ‘Basel IV’.
AAR
Association of Austrian Raiffeisenbanks
Industry association · Austria · EU Transparency Register LIVR-00162not in register snapshot
This register number is the organization’s own declaration on its submission. It is not in the 14 Sept 2026 snapshot of the EU Transparency Register, so we neither link to it nor use it to identify this organization.
3
positions filed
in the 639 files tracked
3
legislative files
of 639 tracked
2
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 639 consultation files tracked so far (53,766 submissions, mostly 2021–26), so an organization's real filing history is larger, not smaller.
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Their record over time
Association of Austrian Raiffeisenbanks filed 3 positions between 22 Feb 2022 and 9 Aug 2023, across 3 of the 639 legislative files tracked here, attaching a full position paper 2 times.
2022 · 1 filed2023 · 2 filed
What they argued
We fully support the objective to strengthen depositor protection and confidence as stated in the Commission's draft legislation. However, the path taken by the EC to achieve these aims is the wrong one. 1. Extension of MREL scope This is particularly true for the proposed extension of the scope of application to smaller and medium-sized banks.
We fully support the objective to strengthen depositor protection and confidence as stated in the Commission's draft legislation. However, the path taken by the EC to achieve these aims is the wrong one. 1. Treatment of IPS The starting point for the Commission to revise the CMDI framework in terms of the treatment of Institutional Protection Schemes (IPS) is the Eurogroup Statement of 16 June 2022.
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Turns up on the same files
Organizations that also filed on at least two of the same consultations. A shared interest in the same dossiers — not evidence of coordination, and we do not suggest any.
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