Finance Denmark

The financial sector plays a central role in supporting European businesses with investments and financing. Finance Denmark fully supports the Commission's work on the Clean Industrial Act and the Industrial Decarbonisation Accelerator Act and its focus on promoting European competitiveness and help energy-intensive industries continue to decarbonise while maintaining their competitiveness internationally.

Finance Denmark overall supports the objective of the proposal, including the ambition to establish a voluntary, harmonised company law framework that companies may choose as an alternative to navigating multiple national regimes. A well-functioning 28th regime may help facilitate cross-border activity and thereby contribute to realising the full potential of the internal market.

Response from Finance Denmark (Finance Denmark is the business association for banks, mortgage institutions, asset management, securities trading and investment funds in Denmark) From a general perspective, Finance Denmark recognises the potential benefits for companies in not having to navigate 27 different national legal frameworks. A harmonised regime could reduce complexity and administrative burdens.

Improvements in energy efficiency of the building stock play an important role in the green transition and decarbonisation in the EU. There is a need to promote energy improvements of existing homes and ensure that new homes are suffi-ciently energy efficient. We generally support measures and initiatives that con-tribute to cost-effective energy efficiency and reduce emissions from buildings.

Finance Denmark supports regulation of AI. It is important to provide a regulation that protects the customer, through which trust in AI can be build. Much of what the financial sector does, is fundamentally based on trust. Therefore, it is important that AI-solution now and in the future can be trusted through a sound and appropriate regulatory framework on AI.

The financial sector plays a crucial role in mobilising the private capital required to deliver the EUs climate and energy objectives towards 2040. This requires clear, stable and investmentfriendly framework conditions at EU level. Finance Denmark supports the Commissions ambition to ensure a robust, competitive and sustainable energy supply in Europe beyond 2030.

Finance Denmark thanks for the opportunity to comment on the Commission’s proposal regarding the delegated acts under the EU Taxonomy. We support the ambition to simplify the framework and reduce unnecessary complexities in application. At the same time, we fundamentally support the intention of the taxonomy as a key tool to support the transition to a more sustainable economy.

Filed in Danish · English published by the European Commission

Finance Denmark supports the Commissions proposal, which contains several positive elements. We welcome a revision that strengthens the focus on investor understanding and improves the usability of sustainability information.

We agree with the limitations of the SFDR the Commission has pointed out in the call for evidence. The objective of the sustainable finance legislation, however, remains fully valid. We therefore support the Commissions efforts to simplify key concepts, streamline and reduce disclosure requirements, and the introduction of clear and simple product categories.

Finance Denmark strongly supports the proposals of sustainable finance and we think The European Commission’s proposals overall are a positive step towards a sustainable economy. The Commission´s initiative is an important part of the steps to achieve the necessary funding for the transition to a low-carbon, resource-efficient and circular economy.

We are overall supportive of the ambitious proposal. It is now important to stay ambitious in the forthcoming political and standard development process. In particular this applies to the following areas: • consistency to requirements to the financial sector • expansion of scope to all large undertakings and all listed undertakings • mandatory standards for large undertakings • proportionate simplified standards for…

We support the EU Commissions work on establishing a road map towards nature credits. Nature credits have the possibility of having a significant impact on financing and investments in nature conservation and restoration projects.

Finance Denmarks response to the Eu-ropean Commissions consultation on the proposal for the Net Zero Industry Act COM (2023)161 and Critical Raw Materials Act COM (2023)160 Finance Denmark welcomes the opportunity to respond to the European Com-missions consultation on the Zero Industry Act and the Critical Raw Materials Act.

Finance Denmarks response to call for evidence for the European Climate Resili-ence and Risk Management Initiative Thank you for the opportunity to provide input for the upcoming initiative. The focus on climate resilience and preparedness, while considering the need for simplification and European competitiveness, is both timely and important.

Finance Denmark welcomes the European Commissions Report on the Competitiveness of the Banking Sector and the Single Market in Banking. The report provides an important basis for strengthening the competitiveness, integration and financing capacity of the European banking sector in support of Europes strategic objectives. Please find Finance Denmarks detailed response and recommendations in the attached submission.

Executive Summary: European banking competitiveness is increasingly constrained by the EUs implementation of Basel 3.1 and a fragmented macroprudential framework. The Basel 3.1 Output Floor is set to become a binding capital requirement for most European IRB banksunlike in other major jurisdictionsthereby raising financing costs and reducing lending capacity.

Finance Denmark (FIDA) supports the aims of the Retail Investment Strategy (RIS) to enhance retail investor participation and protection, and to ensure that investors are offered high-quality advice for products and services, which bring them value for money. However, we are concerned with the narrow focus on costs, and we generally find that the effects of the package might not reflect the Commissions intentions.

The Nordic finance sector in Denmark, Finland and Sweden would like to give the following feedback on the Have Your Say Simplifying EU rules on direct taxation omnibus. At the outset, we would like to emphasize the importance of the forthcoming Tax Omnibus for the competitiveness of European companies.

Finance Denmark has submitted a joint response to the Commission’s consultation together with the Swedish Bankers’ Association and Finance Finland. In the proposal, the Commission has chosen an approach for the output floor that applies the floor also on capital requirements beyond the capital requirements agreed upon at international level.

The importance of and need for credible and high-quality ESG ratings cannot be underestimated when it comes to ensuring an effective sustainable transition of society. In principle, ESG ratings can be just as important for the sustainable transition as traditional credit ratings are for the creditworthiness of different countries and financial institutions.

Extract of the full document in Annex: We welcome the intention to develop an EU digital ID scheme with an ambition to ensure a much greater use of digital authentication across the member states. Particularly, we note that this is supported by broadening the scope of the eIDAS regulation to also cover services offered by private companies.

Finance Denmark welcomes the initiative to revise the 2014 eIDAS Regulation, extending it to the private sector and promoting trusted identities, in general, across Europe. In Denmark, we have had a well-functioning public/private digital ID solution since 2010 called NemID. It is a public private partnership collaboration between the Danish banks and the public sector.

Finance Denmark recognizes that a lot of important steps have been taken with SRD and SRD II but there are still issues that must be addressed. One issue relates to the lack of a common of the term shareholder, which SRD II leaves to national law causing inconsistencies. This means that, in practice, the party identified as the shareholder differs from country to country.

Finance Denmark supports a revision of the Consumer Credit Directive. Consumers are today seeking digital solutions where credit offers must be able to be submitted and signed digitally. If consumers want to obtain information or compare different offers, this is often done online rather than on paper. Of course, legislation should reflect these developments.

Filed in Danish · English published by the European Commission

Finance Denmark welcomes the Commissions Proposal for a Regulation on payment services in the internal market (PSR). We have the following comments to the proposal: Open banking The Commission proposes to continue PSD2's principle that; account servicing payment service providers should allow access by providers of open banking services to payment account data and that this should take place in a non-contractual…

General position Finance Denmark sees an advantage in gathering information that EU companies already today are required to disclose publicly into one single access point allowing investors, lenders etc. easy access to standardized, digital, machine-readable data.

Finance Denmark welcomes the Commission's inception impact assessment regarding the establishment of a European Single Access Point (ESAP). Finance Denmark has three key messages for the proposed ESAP 1. Finance Denmark welcomes the establishment of a European Single Access Point. The first step and top priority should be to ensure access to ESG data.

Finance Denmark welcomes the revised proposal and that it includes issues raised by the sector in previous consultations. We still believe that the buy in regime is very flawed, impossible to implement, unproportionally expensive and ineffective means to improve settlement quality.

Finance Denmark thanks the Commission on the opportunity to provide feedback on the Commission's proposal for a regulation on preventing money laundering and terrorist financing. Finance Denmark supports the Commission’s Anti-money laundering and coun-tering the financing of terrorism legislative package and a new and revised reg-ulatory framework and supervision in the EU, and we strongly agree that in-creased…

The sustainable transformation of society is an important and necessary agenda. Consumers, businesses and the financial sector need to contribute — no one can do this alone. The financial sector is part of all parts of the economy and is therefore an important catalyst for the development of a sustainable Danish economy.

Filed in Danish · English published by the European Commission

Finance Denmark acknowledge that it is evident that there has been a decline in research coverage for small and mid-cap companies, but we do not believe that rolling back the unbundling regime is not the right way to solve this chal-lenge. We see issuer sponsored research as a much better tool to solve this chal-lenge.

Finance Denmark thanks you for the opportunity to submit comments to the consultation, and we support the purpose of the proposed rules. Comment: Art. 1(3)(e), following nature of control over the legal entity, appears to be missing the wording or legal arrangement. Alternatively, it could specify or legal arrangement when data on a beneficial owner is submitted under the option in point (b)(vii).

Finance Denmark supports the Commission’s Anti-Money Laundering and Coun-tering the Financing of Terrorism Package which aims to strengthen the fight against financial crime in Europe and, as an important part of the new initiatives, the establishment of a new EU AML Authority (AMLA). We find harmonisation of the cross-border area crucial.

Finance Denmark supports the European Commission's communication towards a new comprehensive approach to preventing and combatting money laundering and terrorism financing and we appreciate the opportunity to provide our view and feedback.

The EU Commission has proposed a revised European Market Infrastructure Regu-lation. The proposal does not fundamentally alter the role of central counterpar-ties (CCPs) in reducing contagion risk in the derivative markets, but rather aims to encourage further use of EU based clearing houses by allowing them greater freedom in their operations and products, enhance agility in the supervisory framework by easing…

Finance Denmark appreciates the opportunity to provide feedback regarding the amendments to the prudential treatment of securitisation exposures under the Liquidity Coverage Ratio Delegated Regulation. We support the Commissions initiative to revise the eligibility conditions for securitisations in the liquidity buffer of credit institutions.

Finance Denmark appreciates the opportunity to provide feedback on the targeted amendment regarding the prudential treatment of securities financing transactions under the Net Stable Funding Ratio (NSFR). Finance Denmark strongly supports the initiative to make permanent the current transitory prudential treatment for securities financing transactions (SFT) and unsecured transactions with a residual maturity of less…

Finance Denmark thanks the Commission for the opportunity to provide feedback on the proposal. Finance Denmark supports the EU Commission’s Anti-money laundering and countering the financing of terrorism legislative package.

Finance Denmark welcomes and supports the proposal from the Commission in the omnibus package to convert the Settlement Finality Directive into a Regulation. A common regulation provides legal certainty for payments and securities settlement systems in the EU in cross-border situations.

Finance Denmark thanks for the opportunity to provide feedback to the initiaitve Defence Single Market: EU technological base fit for future. The challenges to Europe´s security caused by the recent development in transatlantic relations and the ongoing Russian war of aggression in Ukraine has led to a clear need for Europe to build up its own military capabilities.

Banking Union: Review of Crisis Management and Deposit Insurance framework (CMDI) Executive summary Finance Denmark welcomes the underlying objective of the Commission’s proposal for the Review of the Crisis Management and Deposit Insurance framework (hereafter CMDI), which aims at broadening the application of resolution tools in crisis management at European and national level for all European banks, regardless of…

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

Finance Denmark support the initiative of an EU Strategy for Retail Investors and suggest that the well-being of the investor is put at the center of the strategy. Consumer protection in the context of the CMU is about generating trust and transparency, whilst promoting a better investment and saving culture.

Banking Union: Review of Crisis Management and Deposit Insurance framework (CMDI) Executive summary Finance Denmark welcomes the underlying objective of the Commission’s proposal for the Review of the Crisis Management and Deposit Insurance framework (hereafter CMDI), which aims at broadening the application of resolution tools in crisis management at European and national level for all European banks, regardless of…

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

General remarks to be added The number of Options and National Discretions (ONDs) included in the BRRD (including the BRRD2) implies significant uneven playing field for institutions in certain jurisdictions which also constitute barriers to the function of the internal EU single market.