German Banking Industry Committee

Comments on the insolvency law section (Chapter X) of the European Commission’s proposal for a regulation on the 28th regime corporate legal framework – ‘EU Inc.’ Lobby Register No R001459 EU Transparency Register No 52646912360-95 Contact: [name removed] Telephone: [phone removed] Telefax: [phone removed] E-mail: [email removed] Berlin, 13 May 2026 The German Banking Industry Committee is the joint committee…

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

The German Banking Industry Committee (GBIC) welcomes the European Commissions initiative to improve the usability and proportionality of the EU Taxonomy by revising the delegated acts on climate and environmental objectives.

From the banks perspective, The Cybersecurity Act 2 (CSA 2) represents a paradigm shift: away from a primarily technical and operational focus towards greater consideration of geopolitical risks, and from a technology-neutral approach towards more concrete guidelines for member states, for example regarding the transition to post-quantum cryptography.

Consistency with EU regulation, proportionality and usability: Alignment with existing EU legislation has improved but is not applied consistently. Compliance with existing regulation, including EIA outcomes and permits, should generally be sufficient. Additional requirements create misalignment and unnecessary complexity.

The German Banking Industry Committee welcomes the Commissions proposal, which is aimed at further developing the SFDR to make it a more coherent, user-friendly and effective framework. The introduction of three product categories with relevant requirements improves the current regime. The simplification of disclosure requirements (e.g.

Executive summary The Sustainable Finance Disclosure Regulation (SFDR) is an important instrument in combating climate change. Capital flows are to be steered towards sustainable investments and greenwashing prevented through transparency. The current review of the SFDR should be used to improve transparency and comprehensibility for investors with targeted amendments.

The German Banking Industry Committee fully recognizes that the Cyber Resilience Act will enhance cybersecurity standards of products that contain a digital component, requiring manufacturers and retailers to ensure cybersecurity throughout the lifecycle of their products from 2027 onward. The Commission guidance can help better understand the CRA requirements.

Please find attached the GBIC comments on the European Commissions Digital Omnibus proposal of 19 November 2025. In particular, we would like to draw your attention to our remarks on the proposed new GDPR provision, especially concerning the processing of personal data in the context of AI training, as well as to our recommendations for ensuring that the envisaged uniform cybersecurity incident-reporting mechanism…

- Prerequisites for the EU Single Market from the Financial Sectors Perspective The introduction and high adoption rate of the Business Wallet face various challenges and are subject to relevant prerequisites. Before banks adapt their systems and processes for businesses, the ecosystem surrounding the European Digital Identity Wallets (EUDIW) for natural persons should have been successfully launched.

The German Banking Industry Committee welcomes the European Commissions initiative to establish a legal framework for the potential use of international carbon credits under the European Climate Law. Given the 2040 target of reducing net greenhouse gases by 90% and the planned limited use of high-quality international credits of up to 5%, we believe this initiative is both timely and systemically important for…

The German Banking Industry Committee (GBIC) welcomes the European Commissions proposal for a Market Integration and Supervision Package (MISP). It is the first step in the right direction. GBIC is particularly interested in the proposals that affect post-trade infrastructure and its offerings. Comparison with the US market shows that infrastructure providers in Europe are too complex and costly.

GBIC welcomes the opportunity, provided by the European Commission, to give feedback on this proposal for this Regulation and contribute to the legislative debate. Please find attached our detailed comments and positions on the proposal. The German Banking Industry Committee (GBIC) is the joint committee operated by the central associations of the German banking industry.

The German Banking Industry Committee (GBIC), True Sale International GmbH (TSI), Eurofinas and Leaseurope expressly welcome the European Commission's initiative to revise the securitisation framework as a whole.

We support the replacement of the SFD by a regulation ensuring greater harmonization and the adaptation of new technologies. However, we are concerned that the FCD is not addressed in a similar manner. Detailed Comments: Art. 1 (2): The current approach requiring member state registrations for 3rd country systems should be replaced by a single EU registration to avoid legal uncertainties within the EU. Art.

This submission is made by the German Banking Industry Committee (GBIC), the joint committee of the central associations of the German banking industry representing around 1,700 banks in Germany. It concerns the European Commissions draft implementing act on the onboarding of users to the European Digital Identity Wallet (EUDIW) under eIDAS 2.0.