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.

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 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.

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 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 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…

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 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 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.