German Banking Industry Committee

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…

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…

Comments on the European Commission’s proposal from 19 November 2025 for a Regulation of the European Parliament and of the Council amending Regulations (EU) 2024/1689 und (EU) 2018/1139 as regards the simplification of the implementation of harmonised rules on artificial intelligence (Digital Omnibus on AI) – COM(2025) 836 final Lobby Register No R001459 EU Transparency Register No 52646912360-95 Contact: Dr.

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

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.

The German Banking Industry Committee (GBIC) welcomes the European Commissions efforts to revise the European Sustainability Reporting Standards (ESRS) to create a more targeted, proportionate and operationally feasible framework under the Corporate Sustainability Reporting Directive (CSRD). Compared with earlier drafts, the revised text introduces clear improvements, including better drafting, and clarifications.

Comments On the proposal for a regulation of the European Parliament and of the Council laying down harmonized rules on artificial intelligence (artificial intelligence act) and amending certain union legislative acts Register of Interest Representatives Identification number in the register: 52646912360-95 Our ref Ref. DK: KI Ref. DSGV:8528/01 Contact: Dr.

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

The German Banking Industry Committee is the joint committee operated by the central associations of the German banking industry. These associations are the Bundesverband der Deutschen Volksbanken und Raiffeisenbanken (BVR), for the cooperative banks, the Bundesverband deutscher Banken (BdB), for the private commercial banks, the Bundesverband Öffentlicher Banken Deutschlands (VÖB), for the public banks, the…

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 (GBIC) welcomes the objective pursued by the proposal for a European Data Act, namely to establish a horizontal legal framework to facilitate the access to data for, and the exchange of data between, consumers and businesses. Data-driven innovation and services are becoming increasingly important, both for individual businesses and the European economy as a whole.

Comments On the proposal for a regulation on the establishment of a framework to facilitate sustainable investment Register of Interest Representatives Identification number in the register: 52646912360-95 Our reference Ref.

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

The GBIC welcomes the opportunity to comment on the European Commission's legislative proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Regulation (EU) 2016/1011 on low carbon benchmarks and positive carbon impact benchmarks as regards organisational requirements and operating conditions for investment firms and defined terms for the purposes of that Regulation.

The German Banking Industry Committee (GBIC) welcomes the opportunity to comment on the European Commission's legislative proposal for amending Regulation (EU) 2017/565 supplementing Directive 2014/65/EU of the European Parliament and of the Council as regards organisational requirements and operating conditions for investment firms and defined terms for the purposes of that Directive.

The German Banking Industry Committee supports the planned transformation to a sustainable economy in Europe. The submitted legislative proposal for a “Corporate Sustainability Reporting Directive” is an important step towards harmonised sustainability reporting throughout Europe. Nevertheless, the implementation of the new reporting requirements seems to be rather ambitious, both in terms of content and time.

Dear Sirs/Mesdames, We are taking this opportunity to share with you our considerations on the review of Directive 2014/95/EU. Furthermore, we are very interested in the evolution of non-financial reporting. We believe that the provision of high-quality sustainability information is an important issue.

The German Banking Industry Committee welcomes the proposal of the Alternative Fuels Infrastructure Regulation. If users are to purchase or to use vehicles powered by alternative fuels, it is essential to recharge the cars without difficulties and to pay without unwelcome surprises. In this regard, uniform payment options and convenient ways to pay are essential.

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.

Preliminary remarks The German Banking Industry Committee (GBIC) welcomes the European Commissions goal of a 25 percent reduction in the burden on companies and administrative organizations resulting from reporting requirements.

We welcome that the Commission recognises the central role of the banking sector for the European economy and the need for reform in the regulatory framework. The Communication sends an important signal in favour of greater competitiveness and proportionality. The Commission has thoroughly analysed obstacles to the competitiveness of the EU banking sector and identified many important levers.

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…

On 24 May 2023, the European Commission published a draft for the amendment of the PRIIPs Regulation (PRIIPs Draft) within the framework of its Retail Investment Strategy (RIS). The German Banking Industry Committee (GBIC) welcomes the intention of the European Commission to also revise the PRIIPs Regulation within the framework of the RIS.

The German Banking Industry Committee (GBIC) supports the European Commissions intention to use the retail investment strategy (RIS), developed as part of the capital markets union, to make the securities business more consumer-friendly and thereby encourage retail investors to invest in EU capital markets.

We appreciate to have the opportunity to share our comments how to increase consumer participation in capital markets. GBIC is convinced that consumer participation can only be enhanced when clients are able to choose between commission-based and fee-based advice. Therefore, the GBIC is strictly against a ban of inducements.

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.

With the draft Framework for Financial Data Access (FIDA), the EU Commission aims to facilitate access to customer data for a wide range of financial services. This is intended to promote the exchange of data between companies in the financial sector as a whole. Thus, FIDA sets the regulatory framework for open finance.

The German Banking Industry Committee (GBIC) welcomes the opportunity to respond to the call for evidence on the European Commission’s open finance framework initiative. The following comments supplement our response to the Commission’s targeted consultation on 5 July 2022.

The German Banking Industry Committee welcomes in principle the legislative proposal published on 27 October 2021 by the European Commission, the so-called Banking Package 2021, to implement the final elements of the Basel III reforms in the EU regulatory framework.

DEAR Ladies and Gentlemen, please find the German Banking Industry Committee’s comments on the EU Digital ID Scheme. The comments are written in German, but a convenience translation into English is included. Child regards, [name removed] (DSGV)

Filed in German · English published by the European Commission

We would like to express our concern that the first part of the consultation on Instant Payments (targeted consultation) was published before the end of the deadline for feedback on the Impact Assessment. The SEPA Instant credit transfer ("Instant Payments/ SCT Inst") is an important enrichment of the payments service offering in SEPA, which is well accepted by customers from an actual demand.

The German Banking Industry Committee (GBIC) welcomes the European Commissions objective of strengthening European cloud, AI and data centre capacities and reducing strategic dependencies in key digital infrastructures. High-performing, secure and resilient digital infrastructures are essential for credit institutions competitiveness, operational resilience, customer protection and capacity to innovate.

The German Banking Industry Committee (GBIC) takes this opportunity to express its opinion on the draft proposal of the Consumer Credit Directive (2021/0171) published on 30 June 2021. GBIC shares the goal of the Draft Directive of offering consumers a high level of consumer protection (recital no. 12).

Summary Inadequate scope: In the case of loan agreements of small amounts in themselves above EUR 200, there is, in principle, an extremely high amount of processing costs which is disproportionate to the yield – and this is the case for manageable risks as a whole. Therefore, the revision of the Directive should consider whether the lower limit can be significantly raised.

Filed in German · English published by the European Commission

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.

GBIC welcomes that mandatory buy-ins (MBI) should not initially apply. Buy-ins intend to protect buyers and therefore belong at trading level. A buyer has a right under national law to claim damages including buy-in costs from a failing contractual party. But it would neither be proportionate nor adequate to oblige all aggrieved buyers always to make use of their right to procure the securities elsewhere.

1. Scope of regulation – buy-in procedure requires trading participants/partners in particular? Commission delegated regulation (EU) 2018/1229 explicitly obliges trading participants (Art. 29) or trading partners (Art. 31) to initiate a buy-in.

The German Banking Industry Committee (GBIC) welcomes the opportunity to provide its view on the European Commissions proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Regulations (EU) 2017/1129, (EU) No 596/2014 and (EU) No 600/2014 to make public capital markets in the Union more attractive for companies and to facilitate access to capital for small and medium-sized enterprises…

1. Parts of the previous directive are supposed to be adopted by the regulation, while other aspects of the regulation go beyond the previous directive. However, the regulation often contains referrals to either AMLA or the EU Commission to issue numerous regulatory technical standards (RTS).

The German Banking Industry Committe (Die Deutsche Kreditwirtschaft) welcomes the opportunity to provide feedback to the European Commissions inception impact assessment on adapting liability rules to the digital age and artificial intelligence. Please find our detailed position on this initiative in the attached document.

The German Banking Industry Committee very much welcomes the opportunity to comment on the draft EU Green Bond Standard (EuGBS). Due to the length limitations in the online feedback, we will only highlight some key aspects at this point. Our further comments are outlined in the accompanying document.

We thank you for the opportunity to comment on the draft AMLA regulation. The creation of an EU anti-money laundering authority (AMLA) is to be welcomed, but caution is urged against over-regulation of the financial sector and over-emphasis on formal anti-money laundering provisions.

The German Banking Industry Committee continues to support the European Commissions (COM) initiative to increase the attractiveness and resilience of the EU clearing landscape and therefore generally supports the package of measures set out in the proposals for a regulation amending Regulations 648/2021 (EMIR), 575/2013 (CRR) and 2017/1131 (MMFR) - hereinafter referred to as the Amending Regulation, and a Directive…

The German Banking Industry Committee continues to support the European Commissions (COM) initiative to increase the attractiveness and resilience of the EU clearing landscape and therefore generally supports the package of measures set out in the proposals for a regulation amending Regulations 648/2021 (EMIR), 575/2013 (CRR) and 2017/1131 (MMFR) - hereinafter referred to as the Amending Regulation, and a Directive…

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.

GBIC welcomes the opportunity, provided by the European Commission, to give feedback on this proposal for this Directive 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) shares the objective of offering European consumers a high level of consumer protection and a wide choice of products that meet their needs. Our main concerns relate to the scope in article 1 (need to exclude promotional loans to consumers and to exempt digital formats that are equivalent to face-to-face business), the provision of pre-contractual information (no…

DORA is a step towards harmonisation, which the industry sorely needs. The implementation of EU-wide security standards and harmonised tests and uniform reporting structures is crucial if we are to deepen harmonisation of the single European digital market. Removing national inconsistencies in implementing security standards and in supervisory practices will be key to fostering EU-wide innovation.

Art. 21 still contains no obligation for FIUs to provide specific feedback. However, such feedback is necessary so that obliged entities can improve their suspicious activity reporting practices and thus optimise the prevention of money laundering as a whole. Additional note: The directive – as well as the regulation – does not contain a legal basis for the information exchange and information sharing between banks.

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.

The German Banking Industry Committee (GBIC) welcomes the goal of improving crisis management for credit institutions. However, the changes proposed by the European Commission would considerably impair the performance of the well-established national deposit-based guarantee schemes and call into question the structure of the German banking market. The legislative proposal is therefore rejected in its entirety.

GBIC welcomes the opportunity to comment on the Commission’s roadmap: 1. Inducements A potential ban on inducements would run counter the roadmap’s explicit aim to raise the level of participation by retail investors in financial markets.

The German Banking Industry Committee (GBIC) welcomes the goal of improving crisis management for credit institutions. However, the changes proposed by the European Commission would considerably impair the performance of the well-established national deposit-based guarantee schemes and call into question the structure of the German banking market. The CMDI legislative package is therefore rejected in its entirety.

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.

Dear Sir or Madam, Please find attached the opinion of the German Banking Industry Committee on the Commission’s combined evaluation roadmap/Inception Impact Assessment “Review of the bank crisis management and deposit insurance framework (BRRD/SRMR/DGSD review)”. Yours sincerely, on behalf of the German Banking Industry Committee National Association of [name removed] Dr. [name removed] Dr. [name removed]

I. Deletion of Art. 27 (3) MiFID II The German Banking Industry Committee (GBIC) welcomes the European Commission (EC) legislative proposal dated 25th November 2021 to delete Article 27 (3) MiFID II (RTS 27 reporting). GBIC shares the view of the EC that the RTS 27 reporting provides almost no added value to investors and the public. The decision to abolish the requirements of Art.

The German Banking Industry Committee (GBIC) welcomes the goal of improving crisis management for credit institutions. However, the changes proposed by the European Commission would considerably impair the performance of the well-established national deposit-based guarantee schemes and call into question the structure of the German banking market. The legislative proposal is therefore rejected in its entirety.

The German Banking Industry Committee welcomes the opportunity to comment on the legislative proposals dated 25 November 2021 for a revised MiFIR Regulation (MiFIR). The current review offers an excellent opportunity to further optimise cross-border capital market integration and to boost the competitiveness of the EU27 financial marketplace.

Filed in German · English published by the European Commission