French Banking Federation

The FBF welcomes the European Commissions initiative to simplify, and not to deregulate, the digital legislative framework. This simplification has been widely acclaimed in the financial sector, particularly in view of the need for innovation and competitiveness in an international context and of the cybersecurity rules.

The FBF welcomes this simplification initiative strongly advocated in the financial sector. Simplification should aim at removing juxtapositions or inconsistencies between regulations. This must translate into administrative simplification, which will be accompanied by lower costs for banks, improving their competitiveness in a tense geopolitical context.

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Key messages 1. Exempt retail exposures from DNSH (Do No Significant Harm) and MS (Minimum Safeguards) assessment While the revision of the CSRD will exempt most EU companies from Taxonomy reporting, banks will still be required to collect EU Taxonomy data from retail clients (e.g. mortgages, energy-efficient renovations, car loans.

Key messages 1. Exempt retail exposures from DNSH (Do No Significant Harm) and MS (Minimum Safeguards) assessment While the revision of the CSRD will exempt most EU companies from Taxonomy reporting, banks will still be required to collect EU Taxonomy data from retail clients (e.g. mortgages, energy-efficient renovations, car loans.

The French Banking Federation (FBF) welcomes the European Commissions efforts to further simplify the ESRS, by reducing workload and unnecessary costs for companies. Overall, the proposed simplification of the standards is consistent with the balance long advocated by the FBF between reducing the reporting burden and preserving the ambition of the EU Green Deal and the integrity of the EU sustainable finance…

Dear Sir or Madam, The French Banking Federation supports the objectives of the European Commission’s proposal on the due diligence to enhance respect for human rights and environmental protection, create a level playing field and avoid fragmentation amongst Member States and non-EU companies in Europe.

The French Banking Federation (FBF) supports the European Taxonomy and has welcomed the European Commission's desire for simplification. However, the members of the FBF were very surprised by the proposal to revise the delegated acts of the Taxonomy published in February 2026, for the following two reasons.

FBF Summary Position on the European Commissions proposed SFDR 2.0 Regulation A more detailed version of this response is attached The FBF welcomes the European Commissions proposed revision of the SFDR (SFDR 2.0), noting substantial simplification, clearer terminology and more meaningful product categories.

In the context of the implementation of a fair and equitable data economy defined by the Commission, the Fédération Bancaire Française welcomes the publication of the draft Data Act, in that it lays the foundations for a new pillar for harmonising data sharing at European level, thus helping to strengthen the EU’s digital sovereignty and innovation potential.

Filed in French · English published by the European Commission

The French Banking Federation (FBF) welcome the European Commission’s proposal for a Corporate Sustainability Reporting Directive (CSRD). We would like to support the objective to improve efficiency and reliability of sustainability gaps.

Filed in French · English published by the European Commission

The French Banking Federation (FBF) strongly supports the European Commission initiative to improve the disclosure of non-financial reporting. Financial institutions are both issuers (Non-Financial Reporting Directive requirements) and users (Taxonomy, Disclosure, guidelines on NFRD regarding climate-related information) of non-financial data.

The French Banking Federation (FBF) is the professional organization representing all banks operating in France, comprising 320 member banking institutions, including 115 foreign banks. The FBF welcomes the European Commissions ambition to structure a nature credit market, complementary to carbon credits, to accelerate the mobilization of private capital for biodiversity.

The French Banking Federation welcomes the European Climate Resilience and Risk Management Initiative and its related call for evidence. To provide the most relevant response to this consultation, we would like to highlight several key elements: first, the actions undertaken by banks in financing adaptation (non-exhaustive list); second, the main obstacles encountered in such financing; and finally, a potential…

The French banking sector welcomes the clarifications provided by the European Commission for the banking sector. However, the banking sector wishes to draw the Commissions attention to the persistent risks of regulatory overlap between the CRA, Regulation (EU) 2022/2554 on digital operational resilience in the financial sector (DORA), and other sector-specific regulations (PSD2 , PSR , eIDAS ).

The French Banking Federation (FBF) is very supportive of all initiatives for rationalising and simplifying reporting requirements not only to improve the system but also helping to increase the competitiveness of EU businesses.

The French Banking Federation (FBF) welcomes the European Commission's recognition that prudential rules should be assessed not only through the lens of financial stability, but also through their impact on growth, investment and financing capacity.

European banks are resilient and form a core pillar of Europe strategic autonomy. Yet the post 2008 regulatory framework, continually expanded over the years, has become structurally restrictive. Layers of capital immobilisation and cumulative supervisory add ons significantly reduce banks financing capacity at a time when Europe faces Euros 800 billion in annual investment needs.

As banking institutions and future relying parties of the EUDIW, The French Banking Federation welcomes the European Commissions initiative to gather stakeholders views on the use of the European Digital Identity Wallet for legal entities.

FBF shares the ambitions of the RIS and notably welcomes the provisions aimed at improving transparency and promoting financial education but is extremely concerned about certain provisions of the proposal. It would be regrettable if the RIS were to become an obstacle to the objective for which it was designed: stimulating productive investment by European citizens to finance the green and digital transitions.

Driven by OECD initiatives, the EU tax framework has been significantly reinforced. The DAC has expanded, the anti tax avoidance directive (ATAD) introduced a comprehensive anti-avoidance corpus, and the Pillar Two rules were incorporated into EU law adding another layer of obligations and compliance requirements. These rules are creating significant level playing field challenges.

Europes strategic autonomy requires deeper EU capital markets. The FBF therefore supports the MISP and urges a swift, ambitious agreement. Competitiveness should be embedded as a core objective. The Lamfalussy process should be respected: Level 1 principle based; Level 2 specifying implementation modalities and minimum parameters; Level 3 setting parameter levels and remaining optional.

Europes strategic autonomy requires deeper EU capital markets. The FBF therefore supports the MISP and urges a swift, ambitious agreement. Competitiveness should be embedded as a core objective. The Lamfalussy process should be respected: Level 1 principle based; Level 2 specifying implementation modalities and minimum parameters; Level 3 setting parameter levels and remaining optional.

The French Banking Federation takes note of the FIDA legislative proposal, which aims at promoting a fair and equitable data-sharing economy, following on from the cross-sectoral Data Act and Digital Governance Act. The FBF conducted a rigorous analysis of the proposed regulation and would like to draw the Commission's attention to some strong concerns: A.

The French Banking Federation (FBF) welcomes the proposal of the European Commission for the review of the Capital Requirements Regulation and Directive in the context of the Banking Package. The proposal is not yet in line with the mandate given by the G20, the Council and the European Parliament to the Basel Committee not to lead to a significant increase in capital for all banking communities.

The European transposition of the Dec. 2017 Basel Accord is not merely an issue of banking supervision, but also one of the key issues in defending the sovereignty and competitiveness of the European economy. Banks have significantly increased their financial stability over the last decade (the solvency ratio of French banks, for example, improved from 5.8% to 13.8% between 2008 and 2017).

This initiative is a great opportunity to also address the issue of online fraud from both business and society perspectives, since it is increasingly widespread, with an impact on consumers, contributing to the loss of trust online. In the digital age, driven by the rise of e-commerce and the use of social networks as distribution channels, the online advertising industry is experiencing significant growth.

The French Banking Federation (FBF), in its capacity as a professional organisation representing all banks established in France and comprising 300 member banks of all sizes, French or foreign, appreciates its opportunity to contribute to the European Commission’s work on the draft BEFIT Directive.

Filed in French · English published by the European Commission

The French Banking Federation (FBF), in its capacity as a professional organisation representing all banks established in France and comprising 300 member banks of all sizes, French or foreign, appreciates the opportunity offered to it to contribute to the European Commission’s work on the draft Transfer Pricing Directive.

Filed in French · English published by the European Commission

The French Banking Federation (FBF), in its capacity as a professional organisation representing all banks established in France and comprising 300 member banking companies, of all sizes, French or foreign, appreciates the opportunity to contribute to the European Commission’s work on the draft directive on VAT in the digital era.

Filed in French · English published by the European Commission

The French banking sector fully understands the objective pursued by this European regulation to secure such products for a better consumers protection. This objective is indeed part of the broader strategy to enhance cybersecurity level in Europe, which the banking sector greatly supports, provided that it does not add unnecessary complexity and burdens for operators.

The Fédération Bancaire Française (FBF), as the spokesperson of the French banking sector representing the interests of more than 300 banks operating in France, including large and small, wholesale and retail financial institutions, local and cross-border, welcomes the opportunity to comment on the public consultation on FASTER Directive 2023/0187 on faster and safer withholding tax relief and to provide its…

Filed in French · English published by the European Commission

The French banking community welcomes the European Commission's decision to promote instant payments. However, the European Commission's text proposal on instant payments raises questions at different levels and therefore leads the French banking community to propose adjustments to the four proposed pillars. Please find attached a document that presents the major points of our analysis of the text.

Hello The French banking profession, through its federation FBF (French Banking Federation), wishes to make its contribution and thus respond to the European Commission's consultation on its legislative proposal on the revision of PSD2. To do so, please find attached the "Have your say" on the draft PSD3 Regulation. Yours sincerely, FBF

The French Banking Federation (FBF) welcomes the proposal of the European Commission (EC) establishing the European Single Access Point (ESAP). It will allow banks to access robust, comparable and reliable financial and ESG data in an electronic machine-readable format, and thus help to steer even more effectively their financing and investment portfolios towards sustainability objectives and comply with their…

As part of the tax omnibus package, the European Commission plans to propose a recast of European rules on administrative cooperation in the field of taxation (DAC) to make business easier and faster in Europe by reducing administrative burdens and simplifying implementation.

This note, attached as PDF, aims to provide the position of the French banking sector on the European Commission’s proposal for a Directive establishing rules to prevent the misuse of shell entities for tax purposes and amending Directive 2011/16/EU.

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FBF appreciates the opportunity to comment on the Commission’s delegated directive amending the delegated directive (EU) 2017/593 as regards the regime for research on small and mid-cap issuers (“SMEs”) and on fixed-income instruments to help the recovery from the COVID-19 pandemic.

The French Banking Federation strongly supports the proposal of the EC to reduce uncertainty in European financial markets through a Level 1 modification to the Benchmark Regulation, allowing the Commission to designate replacement rates for contracts that do not contain suitable fallback clauses. We welcome the opportunity to express our recommendations, which aim at supporting financial stability.

The French Banking Federation (FBF), as the voice of the French banking sector representing the interests of over 300 banks operating in France, encompassing large and small, wholesale and retail, local and cross-border financial institutions, welcomes the opportunity to provide comments on the European public consultation on the proposal for a council directive amending directive 2011/16/eu on administrative…

The French Banking Federation (FBF) welcomes the opportunity to express the views of the French banking industry on the call for evidence launched by the European Commission (Commission) on a targeted amendment on the prudential treatment of short-term Securities Financing Transactions (SFT) and unsecured transactions under the Net Stable Funding Ratio (NSFR).

Hello The French banking profession, through its federation FBF (French Banking Federation), wishes to make its contribution and thus respond to the European Commission's consultation on its legislative proposal on the revision of PSD2. To do so, please find attached the "Have your say" on the draft PSD3 Directive. Yours sincerely, FBF

The Profession supported the maintenance of the 2002 Directive, which provides a legal basis and a minimum safety net in the absence of a specific text. It plays its role perfectly without hindering the development of distance selling. We regret the chosen scenario. We have the following main comments: Article 16a: We regret the increase in pre-contractual information in terms of volume and procedures.

Filed in French · English published by the European Commission

The MIS package is a major initiative aimed at achieving both regulatory and operational progress, building on the existing regulatory framework and the philosophy of the SIU, with a view to strengthening the European financial marketplace, improving the efficiency of processing chains, and encouraging long-term investment through favourable market conditions.

These comments have been prepared by the French Banking Federation (FBF) as a reaction to the European Commissions (EC) proposal to review the EU crisis management and deposit insurance (CMDI) framework, which includes four legislative texts Daisy Chains, the Bank Resolution and Recovery Directive (BRRD), the Single Resolution Mechanism Regulation (SRMR), and the Deposit Guarantee Scheme Directive (DGSD).

Preliminary remark French banks have made great efforts to implement the various financial regulations and to improve the quality of services provided to their clients. They are now calling for regulatory stability to focus on priorities such as the completion of the CMU or the financing of the post-Covid recovery.

These comments have been prepared by the French Banking Federation (FBF) as a reaction to the European Commissions (EC) proposal to review the EU crisis management and deposit insurance (CMDI) framework, which includes four legislative texts Daisy Chains, the Bank Resolution and Recovery Directive (BRRD), the Single Resolution Mechanism Regulation (SRMR), and the Deposit Guarantee Scheme Directive (DGSD).

These comments have been prepared by the French Banking Federation (FBF) as a reaction to the European Commissions (EC) proposal to review the EU crisis management and deposit insurance (CMDI) framework, which includes four legislative texts Daisy Chains, the Bank Resolution and Recovery Directive (BRRD), the Single Resolution Mechanism Regulation (SRMR), and the Deposit Guarantee Scheme Directive (DGSD).