European Savings and Retail Banking Group

I. Amendments to Regulation (EU) 2023/2854 the Data Act - New article 32y(5) of Data Act: rather than imposing higher fees on all very large enterprises, they should be directed specifically at gatekeepers, given their dominant role and significant influence over the market. II.

FiDA: In the context of the upcoming FiDA framework, we would like to stress that any potential standards developed by ESOs, as proposed by the Commission, should remain voluntary. We also recommend to: - Narrow down the scope of FiDA, both as to the type of customers (only retail natural persons), and data categories (choose a very limited number of data categories based on evidenced needs of the market) - Ensure…

ESBG welcomes the Commissions proposal to introduce an optional European company form (EU Inc.) as a 28th regime in company law. We support the objective of facilitating cross-border business activities, reducing fragmentation and strengthening the competitiveness of the Single Market.

The European Savings and Retail Banking Group (ESBG) welcomes the opportunity to contribute to this important debate. We appreciate the Commissions initiative to engage stakeholders and hope our remarks will be taken into account. Although the proposal aims to reduce fragmentation, a parallel EU regime would overlap with national corporate laws, creating legal uncertainty and potential forum shopping.

ESBG supports the implementation of the ESRS and the adoption of a voluntary standard. We welcome the Commissions decision not to reopen fundamental technical aspects of the ESRS and to introduce targeted policy guardrails, while stressing the need for clarifications to ensure simplification, legal certainty and alignment with wider EU requirements.

ESBG response to the European Commission consultation on the proposal for a regulation establishing the framework for achieving climate neutrality and amending regulation (EU) 2018/1999 (European climate law) ESBG welcomes the opportunity to comment on the proposal for a regulation establishing the frame-work for achieving climate neutrality by 2050 and amending regulation (EU) 2018/1999 (European climate law).

ESBG welcomes the opportunity to comment on the roadmap of a European Climate Law included in the European Green Deal with the aim of achieving Europe’s economy and society becoming climate-neutral by 2050. We acknowledge the severe consequences that climate change would have on the productivity of Europe’s economy, welfare, health, ecosystems, biodiversity and political stability, and support the need to take…

ESBG Position Paper on the European Commission consultation on the Artificial Intelligence Act ESBG (European Savings and Retail Banking Group) Rue Marie-Thérèse, 11 - B-1000 Brussels ESBG Transparency Register ID 8765978796-80 July 2021 Doc 0454/2021 Vers. 4 I. MIS General comments: A.I.

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

ESBG Position Paper on the Proposal for a Directive of the European Parliament and of the Council on Corporate Sustainability Due Diligence and amending Directive (EU) 2019/1937 ESBG (European Savings and Retail Banking Group) Rue Marie-Thérèse, 11 - B-1000 Brussels ESBG Transparency Register ID 8765978796-80 May 2021 General comments We believe that the Corporate Sustainability Due Diligence Directive (CSDDD) is…

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

ESBG response to the EC Call for Feedback – Cybersecurity Act Review ESBG (European Savings and Retail Banking Group) Rue Marie-Thérèse, 11 - B-1000 Brussels April 2026 Title I: General Provisions, Subject Matter and Definitions Definitions In line with the Commission’s current mandate, ESBG strongly believes in simplification and harmonisation of definitions across European legislations.

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

ESBG welcomes SFDR 2.0 proposal and supports the shift from a disclosure-only approach to clearer product categories. We support removing individual portfolio management and financial advice from scope and welcome the reduction of entity-level disclosures (incl.

The European Savings and Retail Banking Group (ESBG) welcomes the European Commission's data strategy and its commitment to create a single market for data that will constitute a potential source of growth and innovation. A European approach to data is essential to ensure competitiveness, avoid fragmentation of national regulations, and benefit from an effect of scale.

ESBG supports the European Commission’s initiative on promoting sustainable investment products. Sustainable investments are of growing importance in the European Union, which is why European savings and retail banks are addressing the issue in depth.

The European Savings and Retail Banking Group (ESBG) welcomes the opportunity to provide comments on the draft Commission Delegated Regulation amending Regulation (EU) 2017/565 supplementing Directive 2014/65/EU of the European Parliament and of the Council as regards organisational requirements and operating conditions for investment firms.

The European Savings and Retail Banking Group (ESBG) welcomes the European Commissions proposal for a Cyber Resilience Act and supports the goal of only having secure software on the internal market. Banks, as users of the products that fall under the scope of application of this Regulation, support the initiative to guarantee the cyber-resilience of hardware and software products that can be and are acquired by the…

ESBG and its Members fully support efforts to ensure that European digital markets remain fair and open to all innovative service providers. 1. The DMA establishes a set of narrowly defined objective criteria for qualifying a large online platform as a gatekeeper.

The European Savings and Retail Banking Group fully supports the objectives of the Cyber Resilience Act (CRA), especially its focus on ensuring the cybersecurity of products with digital elements. Nonetheless, as reflected in our feedback attached, there are significant overlaps between the CRA and the Digital Operational Resilience Act (DORA), which presents serious implementation challenges for the financial…

ESBG welcomes the European Commissions Communication on the competitiveness of the EU banking sector and the single market in banking. The Communication rightly recognises that a competitive banking sector is essential to finance growth, innovation and strategic priorities, while preserving resilience and financial stability. ESBG supports this balanced and forward-looking approach.

The European Savings and Retail Banking Group (ESBG) welcomes the opportunity to contribute to the simplification efforts of the EUs digital rulebook. Please find attached our contribution, focused on overlapping areas of legislation, harmonization of horizontal and sectoral legislation, implementation timelines and standards and clarification and overlaps in definitions throughout the digital rulebook.

The European Savings and Retail Banking Group (ESBG) welcomes the proposal on a European Business Wallet, in the continuance of the EUDI Wallet. Please find attached our contribution, focusing notably on the impact of the wallet on fraud and risk management.

ESBG supports the European Commission's view that boosting the Capital Markets Union, by strengthening the participation of retail investors in the capital markets, is an essential way to channel private finance into the economy and support the green and digital transitions.

No ban on inducements:we are in favor of keeping the choice between commission-based and fee-based model.The current legal framework on inducements is appropriate to protect clients against potential conflicts of interest.A ban on inducements -that would leave room only for the fee-based model- will inevitably lead to an advice gap for retail clients and only a small number of wealthier investors would continue to…

Dear Sir/Madam, The European Savings and Retail Banking Group (ESBG) welcomes the opportunity to comment on the Commissions call for evidence on simplifying EU direct taxation rules and submits the following remarks. Article 4(3) of the Parent-Subsidiary Directive allows Member States to deny the deduction of participation-related expenses, with a flat-rate cap of 5% of dividends.

The European Savings and Retail Banking Group (ESBG) supports the protection of consumers as well as adapting liability rules to the digital age, thereby setting out a framework for excellence and trust in Artificial Intelligence. However, we understand from the proposed Directive that the presumption of a causal link in the case of fault is mainly a matter of "non-compliance of due diligence duties".

The European Savings and Retail Banking Group (ESBG) took note of the European Commission's proposed Regulation on the Financial Data Access Framework and its commitment to establish clear rights and obligations to manage customer data sharing in the financial sector beyond payment accounts, and to promote innovative financial products and services for users and stimulate competition in the financial sector.

The European Savings and Retail Banking Group (ESBG) positively assesses the banking package proposal issued by the European Commission. It transposes the final elements of the Basel III reforms in the EU regulatory framework and it pursues other prudential and supervisory objectives.

1. General One of the vital underpinnings of ESBG is responsible banking. To that end ESBG supports all legislative and other initiatives that benefit consumers as it is of great importance to ESBG that consumers feel that they are treated fairly. Only then can they genuinely be happy with the services provided to them by ESBG members.

First of all, the European Savings and Retail Banking Group (ESBG) welcomes this consultation as well as the possibility given by the Commission to provide feedback on its proposal for the regulation on the transparency and integrity of ESG rating activities. ESBG would like to stress its commitment to sustainability and its support when it comes to fighting greenwashing.

Extract of full doc in Annex The European Credit Sector Associations welcome the proposal for a regulation establishing a framework for a EU Digital Identity and the high ambitions presented in the initiative as a positive development. The Commission proposal aims to provide an ecosystem of credentials leveraging a new wallet architecture of several ID solutions.

European Savings and Retail Banking Group (ESBG) welcomes the opportunity to provide feedback to the European Commission's consultation on the "New EU system for the avoidance of double taxation and prevention of tax abuse in the field of withholding taxes". ESBG is pleased to provide the comments in the attached document.

Dear Sir/Madam, The European Savings and Retail Banking Group (ESBG) welcomes the opportunity to contribute to the European Commissions consultation on the Shareholder Rights Directive (SRD). In this context, ESBG would like to highlight two key challenges that continue to hinder the effective exercise of shareholder rights in cross-border situations.

ESBG and its Members fully support efforts to increase the uptake of SCTInst and share the view that it could facilitate stronger and more integrated homegrown pan-EU payment solutions. The EC should foster an environment that enables the uptake of instant payments, e.g.

The European Savings and Retail Banking Group (ESBG) welcomes the opportunity to provide feedback on the Cloud and AI Development Act proposal. ESBG welcomes initiatives aimed at reinforcing European technological sovereignty, particularly those intended to reduce strategic dependencies in areas as important as cloud computing and artificial intelligence, which are becoming increasingly important for the provision…

Please find attached the European Savings and Retail Banking Group's response to this public consultation. ESBG represents the locally focused European banking sector, helping savings and retail banks in 21 European countries strengthen their unique approach that focuses on providing service to local communities and boosting SMEs.

The European Savings and Retail Banking Group (ESBG) welcomes the opportunity to provide feedback to the European Commission's legislative proposal for a new Payment Services Regulation. Please consider the attached ESBG position as our formal response to the Have Your Say consultation.

ESBG welcomes the opportunity to comment on the European Commission’s proposal for a Regulation establishing a European single access point (ESAP). The availability of quality, comparable, reliable and public ESG data is currently rather limited and insufficient to meet rising expectations and new legal requirements set to take effect soon.

ESBG would like to thank the European Commission to allow for feedback ahead of its delegated regulation even though we regret that no more time was provided to provide feedback. To elaborate more, please find attached ESBG full response, some key takeaways are highlighted below.

Dear Sir/Madam, Thank you for the opportunity to comment on the European Commission consultation on the Listing Act. The European Savings and Retail Banking Group (ESBG) would like to share with you its reflections and proposals which are outlined in the attached paper below. Best regards, [name removed]

ESBG welcomes the opportunity to comment on the EC’s Roadmap. In our opinion, it is most important that a precise distinction is made as to which companies are to be covered by the digital tax. Therefore, this differentiation should primarily be done based on the core business of a company and based on how the business is conducted.

ESBG applauds the EU's efforts to develop a binding and consistent green bond standard that is linked to the EU Taxonomy. Below you may find some concerns with the current proposal: • The number of organizational requirements in the proposal (fifty provisions deal with the legal framework of external reviewers and other supervisory powers while only thirteen deal with the green bond itself ) exceed the purpose of…

Review highlights three main areas: 1) Removing limitations on the supply side by improving the fund structuring and eligible assets related aspects of the ELTIF framework. We support this in principle – however, the specification of which assets can be invested should not be too much softened.

ESBG supports the Commission’s approach on a revision of the Benchmark Regulation (BMR). The main objective should be granting broader powers to competent authorities at national level or Europe-an to ensure an orderly cessation of a critical benchmark, these powers should include the mandate to continue granting the provision of a critical benchmark using a different methodology or a replacement rate.

ESBG fully supports preventing money laundering and curbing terrorist financing. In ESBG’s view, an urgent and useful next step is an enhanced cooperation between supervisors and regulators as well as a strengthened dialogue between them and the banking industry. It is also key to monitor and assess the proper implementation of the last AML Directives and the ESAs review.

ESBG supports the establishment of an EU regulatory framework for crypto-asset markets as a key priority; especially as crypto-assets are currently not covered by current EU-legislation. As the main features that constitute a crypto-asset are of a digital/virtual nature, relying on cryptography and use of DLT, the question of the legal nature of the, the difference between asset and technology, and the possible…

ESBG welcomes the European Commissions initiative to strengthen the securitisation market as a means to support the EUs broader strategic objectives. To motivate banks and other financial entities to invest in high-quality, low-risk EU asset-backed securities (ABS) is a key step toward normalizing demand in the securitisation market. This can help boost lending to the EUs real economy at more competitive rates.

ESBG and its members generally support the arguments put forward by the European Commission as regards the decision to make permanent the prudential treatment for short-term securities financing trans-action (SFT) and unsecured transactions with a residual maturity below six months. However, it is important to note that said arguments focus largely on secured funding provided to other financial participants.

ESBG supports the scenario chosen by the Commission for its proposal to re-tain the relevant and still valid elements of the DMFSD by integrating them into a broader directive (the Consumer Rights Directive 2011/83/EU which is not currently concerning financial products) and to make some adjustments.

Resolution scope: the EU Commission is undertaking far reaching adjustments in the BRRD, specifically regarding the extension of the application of the resolution mechanism, including small and medium-sized institutions. Thus, the EU Commission aims for a fundamental shift, as resolution was once conceived as a response to "too big to fail", not a concept for small and medium-sized savings and retail banks.

Preventive measures: adjustments in the DGSD within the framework of the CMDI review primarily focus on preventive measures. The Commissions proposal increases the administrative burden of the DGSs as well as the supervisory and resolutions authorities and, consequently, the need for resources.

ESBG strongly supports the modernization of the VAT treatment of financial services as the existing regulations are out-of-date and do no longer reflect current practices in the financial sector. This leads to legal uncertainty and a lack of neutrality.

Please find below ESBG comments to the roadmap: 1. Investor protection ESBG supports the Commission’s analysis that several requirements in MiFID, which were aimed to increase investor protection, prove to be extremely costly and bring little added value for investors.

As a general comment on the CMDI framework, ESBG members generally oppose the review overall for various reasons. An operational and effective liquidity-in-resolution tool: ESBG takes note of the recent initiative of the Single Resolution Board (SRB) to assess banks capacity to measure and report liquidity in resolution including the availability of collaterals eligible for monetary policy and the Emergency…

The European Savings and Retail Banking Group (ESBG) welcomes the initiative to harmonize the definitions of criminal offences and penalties for the violation of EU restrictive measures. We believe it would ensure a more consistent enforcement of restrictive measures between EU Member States, even if this enforcement is not centralized at EU level.