Finance Finland

Finance Finland (FFI) represents banks, life and non-life insurers, employee pension companies, finance houses, fund management companies and securities dealers operating in Finland. Our members also include providers of statutory insurance lines, which account for much of Finnish social security. FFI thanks the European Commission for this opportunity to provide feedback on the EU Taxonomy.

June 2026 1 (2) Ref. Ares(2026)5643242 - 03/06/2026 Finance Finland’s response to the European Commission consultation on the ESRS 6/2026 Finance Finland (FFI) welcomes the opportunity to respond to the European Commission’s consultation on the revised European Sustainability Reporting Standards (ESRS).

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

Finance Finland welcomes the Commission’s proposal on Corporate Sustainability Due Diligence Directive that sets a concrete legal obligation for companies to respect human rights and to protect the environment. We support the objectives of the proposal to advance respect for human rights and environmental protection, as well as to create a level playing field and to avoid fragmentation amongst Member States.

Finance Finland (FFI) welcomes the Commission’s proposal to harmonise and standardise companies’ sustainability reporting. We are in favour of extending the reporting scope to large and listed companies, and to also include SMEs in the scope, although with more proportionate reporting obligations.

Finance Finland is the common voice of the Finnish financial sector and represents the interests of its members. We represent banks, life and non-life insurers, employee pension companies, finance houses, fund management companies and securities dealers operating in Finland.

Finance Finland supports the development of investor protection, but we see that the Commission has not chosen successful means to achieve the goals. The presented problems could be better avoided by strengthening supervision instead of introducing new regulations that hinder the market-based functioning of the capital market.

Finance Finland (FFI) supports efforts towards fair data sharing in which the treatment of different players is based on a true level playing field and reciprocity. The focus of opening up data should not be solely on the financial sector, but broadly on all sectors of society. Data access, sharing and usage should be considered in a broad context, with focus on cross-sectoral data sharing, i.e. the data economy.

Finance Finland strongly welcomes the Commissions initiative to develop a comprehensive EU Action Plan against online fraud. The problem description accurately reflects the current threat landscape across Member States.

The financial sector (Finance Finland; ‘FA’) considers that the proposed BEFIT regulation on the single tax base will, in the long term, increase the administrative burden and costs for groups, rather than reducing them. The FA stresses the need to exclude from the scope of the BEFIT regulation certain operators, such as pension funds and certain investment funds, as are the minimum tax (Pillar 2).

Filed in Finnish · English published by the European Commission

Finance Finland welcomes the European Commission’s initiative to introduce a common EU-wide system for withholding tax on dividend payments. Complicated and different withholding tax processes form a substantial barrier to cross-border investments within the EU and it is important that withholding tax processes should be harmonized.

Finance Finland (FFI) sees that additional time to develop the robust and relevant sector-specific disclosure requirements and third company reporting requirements is needed at this stage. FFIs view is that the postponement of sector-specific standards from 30.6.2024 is justifiable as the first batch of draft standards havent yet been published for commenting.

• Finance Finland welcomes the European Commission’s plan to streamline company reporting (both financial and non-financial) in the EU. We have called for a centralized ESG data register and think that accessibility to sustainability data should be the priority in building ESAP.

For the most part, the amendment proposals related to settlement discipline benefit the sector because they harmonise the operating principles of market participants from different markets. They also promote the simultaneity of securities trade and related payments, which will improve investor protection and reduce the risks of market participants.

Finance Finland (FFI) represents the majority of banks, insurers, finance houses, securities dealers, fund management companies and financial employers operating in Finland. It has 323 member organisations. Finance Finland is not in favour of the Commission's proposal for amendments to the unbundling rules described in the draft delegated directive. FFI sees that the scope of application is too limited.

Finance Finlands response to the European Commissions proposal for amending the EMIR Finance Finland supports the efforts to develop a strong CMU to strengthen the EU and secure the international competitiveness of EU clearing members. The aim should be to create an open EU financial framework that does not punish EU-located companies or weaken their competitiveness compared to companies located in third countries.

Supplementary pensions are important, but there is no need for an EU-level pension product Finance Finland supports the European Commissions objective to promote supplementary pension markets. Finance Finland notes that there is a need to supplement pension provision in Finland as well, despite the strong statutory earnings related pension system.

Please find our full position attached. We support the objective of enhancing legal certainty and harmonisation in relation to settlement finality across the EU. However, as currently drafted, the proposed Settlement Finality Regulation (SFR) raises significant concerns regarding the scope and treatment of netting, particularly contractual closeout netting in bilateral arrangements.

Finance Finland (FFI) welcomes the efforts to improve the Banking Unions crisis management tools. The Commissions proposal has many good suggestions which help improve crisis resolution, such as increasing information exchange between supervisory and resolution authorities.