European Fund and Asset Management Association (EFAMA)

EFAMA welcomes the European Commissions Digital Omnibus proposals and the targeted amendments introduced to the GDPR and the AI Act. Overall, the proposed changes provide useful legal clarification and reduce potential administrative burdens while preserving the core objectives of the existing regulatory framework.

EFAMA welcomes the European Commissions initiative to simplify the EUs digital rulebook and strongly supports efforts to ensure it remains coherent, proportionate, and fit for purpose. Asset managers already face overlapping digital frameworks (i.e. AI Act, DORA, GDPR, MiFID II, UCITS, AIFMD), and simplification is essential to reduce fragmentation and costs.

EFAMA welcomes the opportunity to contribute to the European Commission's initiative to establish a European company. Our views, at this stage, focus on the need to safeguard shareholder rights and to enable effective stewardship policies for all companies accessing public markets. Please find attached our comments.

RESPONSE Brussels, 3 June 2026 EFAMA’s RESPONSE TO EC’S CONSULTATION ON ESRS EFAMA broadly welcomes the European Commission’s proposed simplification of the European Sustainability Reporting Standards (ESRS), while preserving double materiality. As European fund and asset managers, our members occupy a critical dual role: representing both primary users and preparers of sustainability data.

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

Sustainable corporate governance and the role of the investment industry EFAMA, the voice of the European investment management industry, welcomes the Commission’s initiative to improve the EU regulatory framework on company law and corporate governance.

The SFDR has introduced several benefits, especially in terms of transparency. However, it has yet to fully realise its potential in strengthening investor protection and steering capital toward sustainable activities. For us, the much-needed amendments in the revision of SFDR provide a good opportunity to meet the Regulations intended objectives.

Please find attached EFAMA's feedback. EFAMA is the representative association for the European investment management industry. EFAMA represents through its 28 member associations and 62 corporate members close to EUR 23 trillion in assets under management of which EUR 15.6 trillion managed by more than 60,000 investment funds at end 2017.

Please find attached EFAMA's feedback. EFAMA is the representative association for the European investment management industry. EFAMA represents through its 28 member associations and 62 corporate members close to EUR 23 trillion in assets under management of which EUR 15.6 trillion managed by more than 60,000 investment funds at end 2017.

Please find attached our feedback. EFAMA is the representative association for the European investment management industry. EFAMA represents through its 28 member associations and 62 corporate members close to EUR 23 trillion in assets under management of which EUR 15.6 trillion managed by more than 60,000 investment funds at end 2017.

Please see our feedback attached. EFAMA is the representative association for the European investment management industry. EFAMA represents through its 28 member associations and 62 corporate members close to EUR 23 trillion in assets under management of which EUR 14.1 trillion managed by 58,400 investment funds at end 2016.

We agree that the European asset management industry has a role to play in contributing to the sustainability agenda. We see this role in 3 distinctive parts: • First, the asset management industry provides its clients, institutional investors and other asset owners, investment solutions that respond to their investment as well as ESG / impact demands; • Secondly, asset managers can give institutional investors the…

EFAMA welcomes the European Commissions Digital Fitness Check and its objective of reviewing the EU Digital Rulebook. We consider that several horizontal digital regulations overlap with existing financial legislation, creating unnecessary duplication for asset managers. EFAMA therefore encourages the Commission to prioritise simplification and regulatory coherence across the digital rulebook.

EFAMA wholeheartedly supports a retail investment strategy that gives EU citizens the necessary tools and the confidence to put their savings to work by investing in capital markets. In our view, the patchwork of rules currently governing retail investor participation is either misaligned or tends to focus too narrowly on investor protection and on the risks associated with investing.

The Commissions initiative to simplify EU law in direct taxation, with its focus on reducing administrative burdens, eliminating outdated/overlapping rules, and improving consistency and application across Member States, is urgently needed to ensure the EU's competitiveness.

EFAMAs members' concerns are limited to the Digital Reporting Requirements (DRRs) (e.g. electronic invoices) that will be introduced. One of the aims of this DRR element of the proposal is to fight tax fraud (which can be hard to happen in transactions that are VAT exempt).

Environmental, social, and governance (ESG) considerations play a crucial role in asset managers' investment decisions for several reasons: Financial Impact. ESG factors can significantly affect a company's financial success and long-term viability, which in turn can impact investment returns. Investor Demand.

The European Fund and Asset Management Association (EFAMA) supports the objectives of the Shareholder Rights Directive (SRD) I and II and welcomes a targeted revision to address existing identified impediments and ensure greater exercise of shareholder rights.

EFAMA warmly welcomes the publication of the CSDR Refit proposal. The EC has clearly taken onboard the feedback from market participants on the structural flaws in the design of the mandatory buy-in (MBI) regime and its potential for unintended consequences on capital market efficiency and resilience.

EFAMA fully supports this initiative and the Commission’s efforts to encourage more companies to finance their investment through equity contributions rather than debt financing. The Commission decided to follow a policy option that will enable the deductibility of an allowance on equity financing costs complemented by a rule to limit the deductibility of interest on debt financing instruments.

EFAMA is grateful for the opportunity to comment on the Un-shell entities proposal. We are sharing our comments with the Commission, with all Fiscal Attachés/Ministers of Finance of the 27 EU Member States and stands ready to assist and discuss the issues raised in this document with the technical teams of the relevant stakeholders that will work in the upcoming negotiations of this proposal.

EFAMA strongly supports the Commission's draft proposal amending the ELTIF Regulation where it addresses some of the major obstacles that have undermined the attractiveness of the ELTIF product since inception. The revised legal framework has the potential to transform ELTIF into a product of choice for a larger (retail) investor audience, all while serving the purposes of the Capital Markets Union (CMU).

Swift, but… EFAMA appreciates that the European Commission is pursuing an alleviation of certain MiFID II requirements in the interest of promoting a swift recovery from the economic crisis precipitated by the COVID-19 pandemic.

EFAMA believes the following elements require due consideration in the draft implementing regulation (the Draft): 1. Multiple options (Art. 1(3)(b-c)) According to our understanding, the ability to choose multiple options to clarify the nature and extent of the beneficial interest and the beneficial owners (BO) for legal arrangements and legal entities is intended to provide flexibility when more than one option…

The European Fund and Asset Management Association (EFAMA*) welcomes the European Commission’s efforts to work towards an adequate implementation of the EU Anti-money laundering (AML) framework and look forward to engaging on the next steps in the March AML Action Plan.

EFAMA welcomes the European Commission’s review of the Alternative Investment Fund Management Directive (AIFMD), setting out targeted improvements to key provisions in the current framework. Such targeted improvements will make strides in advancing the Capital Markets Union while maintaining the framework which has underpinned a decade of growth in the European Alternative Investment Fund (AIF) market and proven…

EFAMA, the voice of the European investment management industry, represents 28 Member Associations, 60 Corporate Members and 24 Associate Members. At end Q2 2020, total net assets of European investment funds reached EUR 17.1 trillion. These assets were managed by more than 34,200 UCITS (Undertakings for Collective Investments in Transferable Securities) and 29,100 AIFs (Alternative Investment Funds).

EFAMA’s RESPONSE TO EC ROADMAP ON THE AIFMD REVIEW The AIFMD is one of the pillars of EU regulation for asset managers and investment funds, which have a crucial role to play in the development of the Capital Markets Union (CMU) and the post Covid-19 economic recovery in the EU. EFAMA's views are on the roadmap are outlined in the document attached.

EFAMA is grateful for the opportunity to comment on the Pillar Two proposal. We are sharing our comments with the Commission, with all Fiscal Attachés/Ministers of Finance of the 27 EU Member States, as well as with the OECD Secretariat.

EFAMA is grateful for the opportunity to comment on some of the messages included in the European Commission's roadmap on the "Review of VAT rules on financial services". Our comments cover the following sections of the roadmap: - Section A (Box1 - Problem the initiative aims to tackle: the lack of tax neutrality) - Section B (objectives and policy options) - Section C (Preliminary Assessment of Expected Impacts) -…