The Dutch Banking Association appreciates the opportunity to contribute feedback on the proposed regulation regarding sustainable finance disclosure. Below, we highlight our main points. For our detailed feedback on the proposal regulation we refer to our position paper attached to this response.
DBA
Dutch Banking Association
Industry association · Netherlands · EU Transparency Register 51894741860-19
6
positions filed
in the 665 files tracked
6
legislative files
of 665 tracked
6
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 #576 by legislative files engaged, a count of participation, not a measure of influence.
8.2
declared lobbying FTE
self-declared
€1.5M+
declared costs / yr (floor)
3
EP accreditations
as declared to the register
2009
in the register since
Declares membership of
- European Banking Federation: www.ebf.eu
- European Parliamentary Financial Services Forum: www.epfsf.org
- European Mortgage Federation: https://hypo.org/
Self-declared to the EU Transparency Register (snapshot 14 Oct 2026).
- Register category
- Trade and business associations
- Registered as
- Nederlandse Vereniging van Banken / Dutch Banking Association (NVB)
- Head office
- Amsterdam, Netherlands
- EU office
- Brussels
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
Dutch Banking Association filed 6 positions between 21 Jun 2018 and 15 Sept 2026, across 6 of the 665 legislative files tracked here, attaching a full position paper 6 times.
2018 · 1 filed2021 · 1 filed2023 · 1 filed2026 · 3 filed
What they argued
The Dutch Banking Association (Nederlandse Vereniging van Banken, or ‘NVB’) welcomes the opportunity to comment on the amendments to MiFID II delegated act, which is part of the Commission proposals on financing sustainable growth (‘Commissions package’). In essence, the NVB endorses the intention behind the Commissions package’s goals.
The Dutch Banking Association welcomes the European Commissions ambition to strengthen the competitiveness of the EU banking sector and deepen the Single Market in Banking, while preserving resilience. These objectives are urgent: Europe must mobilise substantial private and public investment for the twin transitions, to maintain strategic autonomy and to promote a more competitive economy.
The document in the attachment presents the Dutch Banking Associations feedback on the European Commissions Action Plan against Online Fraud. It expresses strong support for DG HOMEs initiative and highlights several priorities essential for an effective EU wide approach.
The Dutch Banking Association (DBA) would like to make some additional remarks on the Consumer Credit Directive (CDD) proposal. These remarks come in addition to the reaction of the European Banking Federation (EBF).
The Dutch Banking Association shares its views on the Crisis Management and Deposit Insurance (CMDI) proposal which was published on April 18th 2023. The Dutch Banking Association and its members recognise the great importance of an effectively functioning Crisis Management & Deposit Insurance (CMDI) Framework for the adequate unwinding of banks through resolution or bankruptcy.
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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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Everything on this page comes from Dutch Banking Association’s own submissions to the European Commission. We have added nothing and interpreted nothing. If something is wrong or out of date, email info@policyspeak.com and we will correct it. If you are an individual named in a record, our privacy policy sets out your rights to correction, objection and removal.
Quotes are verbatim from submissions published by the European Commission, trimmed to their opening passage and never summarized by a model. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.