European Banking Federation

The European Banking Federation (EBF) appreciates the opportunity to provide feedback to the call for evidence. Please find attached our recommendations on how to ensure a more efficient and coherent regulatory framework that upholds key policy objectives, such as financial stability, data protection and consumer protection, while fostering growth and competitiveness.

Key messages: - Strong business cases for circularity: The Circular Economy Act must correct market failures to create robust, profitable business cases on a large scale. Transitioning to a circular economy not only requires clear recycled content standards and phasing out high-impact materials, but also strong structural economic incentives to reward circularity and stimulate demand, including through public…

The European Banking Federation strongly supports the goal of simplifying and harmonizing the technical screening criteria across the EU regulatory framework. While we support all efforts for simplification, proportionality, practical applicability and consistency with EU law, we believe the proposed simplification is insufficient to significantly improve the usability of the whole Taxonomy framework.

Key messages & proposals We strongly support the goal of simplifying the technical screening criteria, enhancing clarity and coherence, and reducing unnecessary complexity while maintaining robust environmental standards and the overall integrity of the EU Taxonomy framework.

Key messages & proposals We strongly support the goal of simplifying the technical screening criteria, enhancing clarity and coherence, and reducing unnecessary complexity while maintaining robust environmental standards and the overall integrity of the EU Taxonomy framework.

The European Banking Federation welcomes the opportunity to provide its feedback on draft final versions of revised sustainability reporting standards, both ESRS and voluntary standards. Given that we consider EFRAGs proposed ESRS to represent an acceptable compromise, and that a regulatory pause is necessary to allow for implementation assessment and the identification of lessons for a potential post-implementation…

The European Banking Federation (EBF) welcomes the opportunity to respond to the European Commission’s Consultation on its Inception Impact Assessment (IIA) on a Proposal for a legal act of the European Parliament and the Council laying down requirements for Artificial Intelligence (AI). Please see the attached document for our comments.

EBF position paper on the Corporate Sustainability Due Diligence Directive (CSDD) Key points and recommendations: • • 1 We support the objectives of the proposal to advance respect for human rights and environmental protection and embed these aspects into supply and value chains, to create a level playing field and to avoid fragmentation amongst Member States (MS).

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

The European Banking Federation strongly supports the goal of simplifying and harmonizing the technical screening criteria across the EU regulatory framework. While we support all efforts for simplification, proportionality, practical applicability and consistency with EU law, we believe the proposed simplification is insufficient to significantly improve the usability of the whole Taxonomy framework.

The European Banking Federation strongly supports the European Commissions efforts to reduce the complexity of sustainability-related disclosures for capital markets and increase their usability for both investors and financial market participants.

The SFDRs objectives are still relevant. However, there are many shortcomings with the interpretation and implementation of existing requirements, and we welcome the upcoming revision of the SFDR to strengthen the effectiveness of the regulation. We have set out recommendations to improve the framework's usability and transparency for end-investors, with a particular focus on retail investors. Our key messages: 1.

The European Banking Federation (EBF) welcomes the opportunity to comment on the European Commission’s Inception Impact Assessment (IIA) on the Data Act and continues to support its ambition to build a Single Market for Data in Europe. Making more data available and improving the way in which data is accessed and used is essential for tackling a wide array of challenges.

The European Banking Federation (EBF) welcomes the opportunity to respond to the European Commission’s consultation on its published Data Governance Act. While the EBF recognizes that the different elements of the Regulation are a step towards helping to create a Single Market for Data in the EU, we would encourage more ambition in future proposals, notably on the Data Act, to increase access data across different…

The European Banking Federation (EBF) supports the European Commission’s ambition to create a single market for data in the EU and welcomes the opportunity to respond to the Commission’s Inception Impact Assessment (IIA) on a Legislative Framework for the governance of common European Data Spaces.

July 2021 Corporate Sustainability Reporting Directive: Preliminary views for the European Banking Sector Submission to the European Commission’s request for feedback The EBF welcomes the European Commission's proposal for the Corporate Sustainability Reporting Directive.

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

The NFRD should take th form of a Regulation, to ensure harmonization and efficiency. EU should start the work of standardizing the format and the structuring of companies’ ESG reporting, building on the existing market tested models and practices.

The European Banking Federation (EBF) welcomes the European Commission’s initiative to address the issues with regard to large online platforms with significant network effects acting as gatekeepers and welcomes the opportunity to respond to the published Inception Impact Assessment (IIA) on a possible ex-ante regulatory instrument.

The European Banking Federation strongly supports the goal of simplifying and harmonizing the DNSH principle across the EU regulatory framework including its application under the MFF. We support all efforts for simplification, proportionality, practical applicability and consistency with EU law.

The European Banking Federation (EBF) welcomes the opportunity to put forward our comments on the European Commissions call for evidence on its initiative for the rationalisation of reporting requirements. The EBF is very supportive of all efforts for rationalizing and simplifying reporting requirements not only to improve the system but also helping to increase the competitiveness of EU businesses.

Comments provided in this HYS do not supersede the EBF response to the EC consultation of 19th April 2026. The EBF welcomes the ECs Communication on bank competitiveness and reiterates its call for an ambitious banking package. The EC has identified the right challenges to EU bank competitiveness and set a direction going forward.

The European Banking Federation (EBF) welcomes the opportunity to contribute to the European Commissions simplification initiative under the Digital Fitness Check. In the attached document, we conducted an examination of 11 legal acts, identifying interplays, overlaps and priority areas for the financial sector where simplification, better coordination and effective enforcement are needed, with the objective of…

The European Banking Federation (EBF) shares the European Commission’s opinion that the different approaches of Member States in implementing the NIS Directive have led to significant inconsistencies and fragmentation in the regulatory landscape, which are in turn undermining the level playing field for some operators and leading to further fragmentation of the Single Market.

The European Banking Federation (EBF) welcomes the opportunity to comment on the European Commission's Call for Evidence for an Impact Assessment on a European Business Wallet. The EU Business Wallet initiative holds significant potential to deliver positive impact across numerous scenarios - from reducing administrative burden and compliance costs, to enhancing cross-border interactions for economic operators and…

The European Banking Federation supports the development of a European legal framework for the limited and complementary use of international emission credits that can support global decarbonization financing and contribute to a cost-efficient and politically durable European climate framework - provided they remain strictly supplementary, meet the highest integrity standards and are embedded in a transparent…

The EBF supports the objective of the RIS to enhance retail investor safe participation in EU capital markets. The EBF appreciates proposed elements like digital-by-default communication, efforts to streamline disclosures and further financial literacy, but expresses substantial concern over the complexity, unclear implementation pathways, and negative impacts that far-reaching measures may produce without being…

The European Banking Federation (EBF) stresses that, in an increasingly fragile economic and geopolitical context, simplifying the EUs corporate income tax framework is an urgent priority. Current rules impose disproportionate compliance burdens on EU businesses, undermining their global competitiveness.

The EBF welcomes the publication of the Market Infrastructure Package (MIP). By addressing key sources of persisting fragmentation, the Package creates an opportunity to develop even better conditions for markets to operate on a greater scale and efficiency. In doing so, the MIP prepares the ground for ambitious, demand-oriented reforms to maximize their potential to the markets.

The European Banking Federation (EBF) welcomes the opportunity to comment on the European Commission’s Call for Evidence on an “Open Finance Framework – enabling data sharing and third-party access in the financial sector.” A European data economy which unlocks new opportunities for customers – individuals and firms – through increased data sharing is a priority that the European banking sector welcomes in the…

The European Banking Federation (EBF) welcomes the intention of the European Commission, in the context of the Banking Package, to also bring more clarity to some aspects related to resolution. However, after an initial analysis of the draft text, we are of the opinion that some technical aspects, described in more detail in the file attached, would deserve additional consideration.

The Banking Package should strike the right balance between meeting the fundamentals of the Basel Committee reform, keeping the capital requirements for banks without any significant increase as mandated by the G20 and reiterated by the European Parliament and the European Council and, also, observing key European specificities.

The European Banking Federation (EBF) welcomes the opportunity to provide feedback on the Call for Evidence on the European Commissions Action Plan on Fighting Online Fraud. The EBF is the voice of the European banking sector which already invests heavily in fraud prevention and control.

The European Banking Federation (EBF) welcomes the opportunity to provide additional input on the Commissions proposal for Business in Europe: Framework for Income Taxation (BEFIT). EBF is supportive, in principle, of the idea of comprehensive and uniform European tax regulation, particularly one that aims to address cross-border obstacles in the corporate tax field.

The European Banking Federation welcomes the opportunity to respond to the Have Your Say on the European Commission's proposal for a Regulation on the transparency and integrity of Environmental, Social and Governance (ESG) rating activities. We share our views in relation to the proposal in attachment.

The EBF welcomes efforts at simplification and digitisation of withholding tax processes within the Union. Slow and complex withholding tax reclaim processes remain barriers to efficient investment. A simple, swift, and safe system would encourage intra-union and foreign investment. Nevertheless, the proposed rules remain complex and would require significant due diligence and reporting.

The EBF and its members have extensively contributed to the consultations prior the CCD review. Regrettably, proposals for improvement on technological developments or administrative burden have not been considered. This is a missed opportunity to further integrate and modernise credit markets in Europe. A successful and efficient lending framework should consider both the needs of clients and providers.

EBF Key Messages on ESAP The EBF welcomes and supports the proposal to establish ESAP to provide investors with a common database for financial and sustainability information that EU companies are required to publish pursuant to EU regulation.

For the further details, please see the full text attached. The EBF welcomes the initiative of the European Commission (EC) to propose changes to CSDR with a view to enhance the efficiency of EU’s settlement markets. In particular, the EBF welcomes the decision not to implement MBIs immediately and to prioritize the use of cash penalties.

EBF Members welcome the possibility to provide feedback on the review of EU rules to improve the cross-border provision of settlement services in the EU, which they see as a key component of the 2020 Capital Markets Union Action Plan. In this context, EBF members are of the view that a top priority level should be given to the review of the settlement discipline framework.

The EBF agrees with the over-arching goal of mitigating the tax induced debt-equity bias in corporate investment decisions to render financing more accessible to EU business and to promote the integration of national capital markets into a genuine single market. However, in order to promote economic growth and achieve the goals of the proposal, we recommend the following changes.

Banks are central to the functioning of the Automatic Exchange of Information (AEOI) system, as they carry out due diligence and reporting obligations that enable tax authorities to combat tax evasion. Global and EU tax transparency rests on a dense framework combining FATCA, the OECDs Common Reporting Standard (CRS), the Crypto-Asset Reporting Framework (CARF), and the EU Directive on Administrative Cooperation…

The European Banking Federation (EBF) is fully supportive of the Commission’s overarching objective to address the ineffectiveness of the current EU AML framework. Bearing in mind the necessary lead-time and efforts to get the AML Package adopted and implemented, this momentum is a unique opportunity to improve the framework and cannot be missed. The EBF believes that there is a crucial need for a paradigm shift.

The problems of the initiative for an EU Digital Levy aims to tackle are the same that are at the basis of the work performed in the context of OECD BEPS action 1 and the latest OECD pillar 1 blueprint and of the EU DST proposal that was first issued in March 2018.

The European Banking Federation (EBF) fully supports the EU’s general policy objective to curtail fraudulent and tax abusive behaviour. However, this new anti-tax avoidance initiative raises some concerns, both conceptually and technically.

EBF welcomes the EU Commission proposal to amend MiFID II delegated Directive (EU) 2017/593 aiming at easing the funding of researche unbundling regime for the of execution services and investment research regarding small and midcap issuers and fixed income instruments.

The European Credit Sector Associations (European Association of Co-operative Banks, European Banking Federation, and European Savings and Retail Banking Group - ECSAs) are supportive of the ambition to establish a coherent Europe-wide framework for digital identity (eIDAS 2.0).

We welcome the European Commission’s decision to provide for the possibility to designate one or more statutory replacement rate for benchmarks, whose cessation would result in a significant disruption in the functioning of financial markets in the Union (BMR statutory replacement).

The European Banking Federation (EBF) supports the objectives of the European Commission’s Anti-Money Laundering and Countering the Financing of Terrorism Package which aims to strengthen the fight against financial crime in Europe. The set-up of a new EU AML Authority (AMLA) is a crucial component of this package.

Dear Sir/Madam, Please find enclosed a word (light) version of "LIFTING THE SPELL OF DIRTY MONEY", EBF BLUEPRINT FOR AN EFFECTIVE EU FRAMEWORK TO FIGHT MONEY LAUNDERING A full pdf version is available at: https://www.ebf.eu/wp-content/uploads/2020/03/EBF-Blueprint-for-an-effective-EU-framework-to-fight-money-laundering-Lifting-the-Spell-of-Dirty-Money-.pdf Best regards, [name removed]

The European Banking Federation (EBF) is in favour of a level playing field for all types of assets and financial service providers, including Crypto-Assets, however this should not unproportionally increase the compliance burden on financial institutions (FIs).

The European Banking Federation (EBF) believes that the Regulation on Markets in Crypto-assets (“MICA”) definitional framework should be used as the starting point for the extension of DAC 2 to crypto-assets. It should be mapped to the DAC 2 definitional framework. Using a uniform definitional framework will be a key factor in a successful application of DAC 2 reporting on crypto-assets.

In keeping with the Capital Markets Unions objective to foster well-functioning and internationally competitive EU capital markets, the European Banking Federation (EBF) fully supports the development of a better integrated and more attractive clearing landscape in the EU, and thus welcomes the legislative package set forth by the European Commission on December 7th, 2022.

The EBF would like to thank the European Commission for the opportunity to share feedback on the proposed Regulation on Markets in Crypto-assets. Please find attached a paper with key messages, for consideration of EU institution in the legislative process.

The European Credit Sector Associations (European Association of Co-operative Banks, European Banking Federation, and European Savings and Retail Banking Group, ECSAs) are supportive of the ambition to establish a coherent Europe-wide framework for digital identity (eIDAS 2.0).

The European Credit Sector Associations (European Association of Co-operative Banks, European Banking Federation, and European Savings and Retail Banking Group - ECSAs) are supportive of the ambition to establish a coherent Europe-wide framework for digital identity (eIDAS 2.0).

The European Banking Federation supports the initiative to make permanent the current transitory prudential treatment for securities financing transactions (SFT) and unsecured transactions with a residual maturity of less than six months, with financial customers, for the purpose of the Net Stable Funding Ratio (NSFR).

The European Credit Sector Associations (European Association of Co-operative Banks, European Banking Federation, and European Savings and Retail Banking Group - ECSAs) are supportive of the ambition to establish a coherent Europe-wide framework for digital identity (eIDAS 2.0).

The EBF takes note of the newly published EC proposal for reform of the financial services distance-selling. One of our principal key priorities, in view of this reform, is to be clarified which rules apply in cases when the new Directive overlaps with other European legislative acts, namely the product-specific legislation.

The European Banking Federation (EBF) welcomes the opportunity to share views on the Commission’s proposal of a Regulation on Digital Operational Resilience for the financial sector (DORA). Based on the EBF key messages on DORA, the following positions and suggestions of amendments reflect the current understanding of European banks.

The European Banking Federation (EBF) is fully supportive of the Commission’s overarching objective to address the ineffectiveness of the current EU AML framework. Bearing in mind the necessary lead-time and efforts to get the AML Package adopted and implemented, this momentum is a unique opportunity to improve the framework and cannot be missed. The EBF believes that there is a crucial need for a paradigm shift.

The European Credit Sector Associations (European Association of Co-operative Banks, European Banking Federation, and European Savings and Retail Banking Group - ECSAs) are supportive of the ambition to establish a coherent Europe-wide framework for digital identity (eIDAS 2.0).

The European Credit Sector Associations (European Association of Co-operative Banks, European Banking Federation, and European Savings and Retail Banking Group - ECSAs) are supportive of the ambition to establish a coherent Europe-wide framework for digital identity (eIDAS 2.0).

The European Credit Sector Associations (European Association of Co-operative Banks, European Banking Federation, and European Savings and Retail Banking Group - ECSAs) are supportive of the ambition to establish a coherent Europe-wide framework for digital identity (eIDAS 2.0).

The EBF supports the completion of the Banking Union. To this end, the BRRD/SRMR/DGSD framework should be amended to address the issues identified in this Roadmap. In addition to a shared, strong and well-balanced system to protect depositors, we also urge the Commission to add building blocks which the last years have shown are still missing.

The European Credit Sector Associations (European Association of Co-operative Banks, European Banking Federation, and European Savings and Retail Banking Group - ECSAs) are supportive of the ambition to establish a coherent Europe-wide framework for digital identity (eIDAS 2.0).