Our association welcomes the European Commissions renewed focus on strengthening the competitiveness of the European banking sector. A strong, competitive and well-functioning banking sector is essential to supporting investment, economic growth and financial stability across the European Union.
AFB
Association of Foreign Banks in Germany
Industry association · Germany · EU Transparency Register 95840804-38
13
positions filed
in the 665 files tracked
11
legislative files
of 665 tracked
12
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 665 consultation files tracked so far (57,774 submissions, mostly 2021–26), so an organization's real filing history is larger, not smaller.
Who they are
Among the 1518 trade and business associations on this site, they rank #301 by legislative files engaged, a count of participation, not a measure of influence.
0.7
declared lobbying FTE
self-declared
€100K+
declared costs / yr (floor)
0
EP accreditations
as declared to the register
2008
in the register since
Declares membership of
- www.strukturgesellschaft.de
- www.ibf-frankfurt.de
- www.ifa-deutschland.de
Self-declared to the EU Transparency Register (snapshot 14 Oct 2026).
- Register category
- Trade and business associations
- Registered as
- Verband Internationaler Banken in Deutschland e.V. / Association of International Banks in Germany (VIB)
- Head office
- Frankfurt am Main, Germany
Self-declared to the EU Transparency Register (snapshot 14 Oct 2026); cost bands are floors, not audited totals. Reused under Commission Decision 2011/833/EU.
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Their record over time
Association of Foreign Banks in Germany filed 13 positions between 15 Feb 2021 and 17 Sept 2026, across 11 of the 665 legislative files tracked here, attaching a full position paper 12 times.
2021 · 6 filed2022 · 1 filed2023 · 4 filed2026 · 2 filed
What they argued
Dear Sir or Madam, We highly appreciate the opportunity to provide input to the review of the EU rules on the security of network and information systems. Please find enclosed our position paper on the following topics: (A) Classification of small and non-complex credit institutions as important entities according to Annex 2 (B) Reference to DORA in order to increase legal certainty (C) Clarification on the…
The Association of International Banks in Germany e.V. (VIB) welcomes the opportunity to comment on the Market Integration Package (MIP) presented by the European Commission on 4 December 2025. The MIP forms part of the Savings and Investments Union (SIU), through which the European Commission aims to remove barriers to cross-border capital market activities and further deepen the integration of the Single Market.
Please find attached the Position Paper of the Association of Foreign Banks in Germany (VAB) of 1 November 2023 on the Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on a framework for Financial Data Access and amending Regulations (EU) No 1093/2010, (EU) No 1094/2010, (EU) No 1095/2010 and (EU) 2022/2554 [COM (2023) 360/Procedure 2023/0205/COD].
Filed in German · English published by the European Commission
Art. 4 (1) point (145) CRR should be amended as to include a de minimis threshold. Institutions with a balance sheet total of under € 750 million should be able to obtain the status as small and non-complex regardless of whether the criterion (f) is met, according to which more than 75 % of both the institution's consolidated total assets and liabilities, excluding in both cases the intragroup exposures, must relate…
Please find attached the Position Paper of the Association of Foreign Banks in Germany of 5 January 2023 on the Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Regulations (EU) No 260/2012 and (EU) 2021/1230 as regards instant credit transfers in Euro.
Dear Sir or Madam, We appreciate the opportunity to provide input to the inception impact assessment document Ares(2021)1648321 on Instant Payments. Please find enclosed our position paper of 7 April 2021 concerning the following topics: (i) Directive or Regulation (ii) Implications of mandatory adherence to SEPA Instant Credit Transfers (iii) Compliance risks for PSPs (iv) Voluntary adherence as an alternative Kind…
Please find attached the Position Paper of the Association of Foreign Banks in Germany (VAB) of 1 November 2023 on the Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on payment services in the internal market and amending Regulation (EU) No 1093/2010 [COM (2023) 367 / Procedure 2023/0210/COD].
The Association of Foreign Banks in Germany (VAB) represses the interests of current more than 200 foreign banks and other financial services institutions which operate in Germany via subsidiary or branch. All member institutions are therefore part of a cross-border banking of financial group.
Filed in German · English published by the European Commission
Dear Sir or Madam, Please find attached the Position Paper of the Association of Foreign Banks in Germany dated 18 May 2021 with respect to the proposal for a Regulation on digital operational resilience for the financial sector (DORA).
Dear Sir or Madam, We support the Commission’s plans regarding to put in place regulation addressing digital operational resilience on a union-wide and uniform manner, especially to reach a more coherent level of ICT risk policy in comparison to today’s minimum harmonisation directives or principled-based regulations.
The Association of Foreign Banks in Germany (VAB) represents the interests of currently more than 200 foreign banks and other financial services institutions which operate in Germany via subsidiary or branch. Almost all member institutions are therefore part of a cross-border banking of financial group.
From our Associations point of view, we would like to comment on two critical points in the CMDI package as follows: 1. It is planned to amend Art. 31(2)(d) BRRD in a way that the protection of all depositors is made a resolution goal in the future (full protection of all depositors) and not only the protection of depositors covered by the deposit protection schemes. 2. Draft Art.
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