BETTER FINANCE

BETTER FINANCE welcomes the EC consultation on an optional, digital-by-default 28th Regime framework, including the potential creation of an EU company brand. Properly designed (and as BETTER FINANCE has long advocated for listed issuers) such a regime could bridge corporate and securities law through simplification, reduce arbitrage, overcome (retail) investors home bias, enhance issuer visibility, and ultimately…

BETTER FINANCE welcomes the Commissions effort to improve the usability of the EU Taxonomy technical screening criteria under the Environmental Delegated Act. Clearer and more workable criteria can strengthen the effectiveness of the framework for both reporting entities and end-users of sustainability disclosures.

BETTER FINANCE supports efforts to simplify sustainability reporting requirements and recognises the objective of ensuring that reporting frameworks remain proportionate and operationally feasible. Simplification can contribute to the competitiveness of European businesses and reduce unnecessary administrative burdens.

Ref: EU Commission consultation on Artificial Intelligence (AI)- Ethical and Legal requirements Link to consultation: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12527-Artificialintelligence-ethical-and-legal-requirements_en BETTER FINANCE’s feedback on the EU Commission proposal on Regulation laying down harmonised rules on artificial intelligence (artificial intelligence act) and…

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

Ref: Sustainable Corporate Governance Link to consultation: https://ec.europa.eu/info/law/better-regulation/have-yoursay/initiatives/12548-Sustainable-corporate-governance BETTER FINANCE’s feedback on Sustainable Corporate Governance (inception impact assessment for an EU directive proposal) About BETTER FINANCE BETTER FINANCE, the European Federation of Investors and Financial Services Users, is the European public…

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

BETTER FINANCE welcomes the review of the EU Taxonomy Climate Delegated Act and supports targeted efforts to improve the usability of the technical screening criteria for climate change mitigation and climate change adaptation.

BETTER FINANCE welcomes the European Commissions proposal to revise the Sustainable Finance Disclosure Regulation (SFDR) and the move towards a clearer product categorisation framework. This is an important step towards improving legal certainty, limiting greenwashing and helping retail investors better understand the sustainability profile of financial products.

BETTER FINANCE welcomes the European Commissions plan to revise the SFDR to fix its complexity, legal gaps, and greenwashing risks. As the voice of EU citizens as financial services users, we back a clearer, simpler, and more effective framework that helps individual investors make informed sustainable investment decisions.

BETTER FINANCE welcomes this opportunity to comment on the European Commission proposal on the establishment of a framework to facilitate sustainable investment. EU citizens as savers and individual investors are the main provider of long term funding to the EU economy and are mostly by nature long term oriented, as their needs are often long-term ones: pension, home purchase, children education, etc.

BETTER FINANCE welcomes this opportunity to comment on the European Commission’s regulation proposal on disclosure relating to sustainable investment and sustainability risks (amending Directive (EU) 2016/2341).

BETTER FINANCE welcomes this opportunity to comment on the Commission proposal on low carbon benchmarks and positive carbon impact benchmarks released as part of the Sustainable Finance Action Plan of the European Commission.

BETTER FINANCE welcomes this opportunity to comment on the proposal amending Delegated Regulation (EU) 2017/565 supplementing MiFID II as regards organizational requirements and operating conditions for investment firms and defined terms for the purpose of that directive. Investment firms shall act in accordance with the best interest of their clients.

BETTER FINANCE welcomes this opportunity to comment on the proposal amending Delegated Regulation (EU) 2017/2359 to include the customer’s ESG preferences in the criteria and practical details to be taken into account by insurance intermediaries and insurance undertakings when assessing the suitability of insurance-based investment products for their customers.

BETTER FINANCE welcomes this impact assessment aiming at ensuring that material sustainability factors are consistently taken into account and disclosed by institutional investors and asset managers. BETTER FINANCE agrees with the European Commission on the fact that increasing the transparency of the integration of sustainability in the investment process of asset managers and institutional investors will lead to…

Ref: Corporate Sustainability Reporting Link to consultation: https://ec.europa.eu/info/law/better-regulation/have-yoursay/initiatives/12129-Corporate-Sustainability-Reporting_en BETTER FINANCE feedback on Corporate Sustainability reporting About BETTER FINANCE BETTER FINANCE, the European Federation of Investors and Financial Services Users, is the public interest non-governmental organisation advocating and…

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

BETTER FINANCE supports the Citizens' Omnibus initiative as an opportunity to ensure that EU financial services rules and markets work more effectively for individual investors, savers and pension beneficiaries.

BETTER FINANCE supports the direction of the Master Regulation to integrate EU capital markets, with less cross-border friction and a stronger supervisory architecture. From our perspective, its value should lie in lowering costs through less intermediation, more efficient post-trade/trading structures, and better access to products and markets across borders.

BETTER FINANCE supports the objectives of the MISP package and broadly welcomes the effort to remove barriers to cross-border activity and liquidity, streamline distribution, and reduce unnecessary intermediation, while preserving competitive markets. We also support the EC goal of widening access to investment opportunities and improving capital raising across the EU.

BETTER FINANCE position and recommendations The draft Regulation urgently needs to: expand protection provisions for retail investors against greenwashing; establish a minimum sustainability requirement for ESG ratings to ensure certain degree of harmonisation between providers going beyond transparency of methodology; include a requirement which can address conflicts of interest by integrating clearly labelled…

For BETTER FINANCE, the ECs FASTER Proposal can bring procedural progress in addressing longstanding obstacles to tax recovery for investors dealing with their cross-border investment income. We welcome an EU-wide framework to streamline withholding tax refund modalities.

BETTER FINANCE welcomes the stated objectives of the listing act review for prospectus standardisation and streamlined IPO cost reduction, particularly for SMEs. Investor protection both relies on reporting that must be adequate, accessible and on fair treatment.

BETTER FINANCE, as the leading representative of individual investors interests to European Union (EU) institutions, wishes to share some comments on the Commissions intention to review the framework applicable to venture and growth capital funds.

BETTER FINANCE welcomes the Commissions proposals to amend the Regulation on a Pan-European Personal Pension (PEPP) product. As longtime supporters of the PEPP, we are pleased to see that the Commission remains committed to ensuring that a simple, cost-efficient personal pension product (PPP) is made available to EU citizens to complement the existing offer of PPPs in each Member State.

BETTER FINANCE welcomes the Commissions proposed amendments to the IORP II framework. Occupational pension schemes hold great potential to improve European citizens retirement income as well as to deepen the EUs capital markets, which we believe the proposed amendments will contribute to realise.