European Savings and Retail Banking Group

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 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.

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…

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.

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.

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.

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.

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 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.