Swedish Bankers' Association

The Swedish Bankers’ Association represents banks and financial institutions established in Sweden. Our aim is to contribute to a sound and efficient regulatory framework that facilitates for banks to help create economic wealth for customers and society.

European Consumers should not be subjected to misleading marketing practices or unfair contracts. Such market practices are not only against the interests of individual consumers and households but also result in unfair competition.

Finance Sweden welcomes the Commissions initiative to strengthen the competitiveness of the EU banking sector and the single market in banking. A resilient, diverse and well-integrated banking sector is essential for financing the European economy.

A strong focus on competitiveness and level playing field is needed for banks to be able to finance the EUs strategic goals and to enable European banks to compete internationally. Main recommendations for level playing field in banking regulation are 1.

The Swedish Bankers' Association endorses the EBF's response to the EC's consultation on the framework for Financial Data Access (FIDA) but wishes to underline some additional key points as outlined below (see also attached file). In the financial sector, the concept of data sharing within the context of FIDA demands careful consideration and precision in its execution.

Data protection and respecting the GDPR principles need to be the focus of any initiative in the data sharing area especially as data literacy amongst consumers is still at a low level. It’s vital to ensure that the customer understands which consents they approve and to whom and on a regular basis receive an update of said consents and how to manage these.

The Swedish Bankers’ Association has submitted a joint response to the Commission’s consultation together with Finance Denmark 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.

Finance Swedens input to the Commission initiative Fighting online fraud action plan 13 March 2026 Finance Sweden has been given the opportunity to provide input on the Commission initiative Fighting online fraud action plan: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/16313-Fighting-online-fraud-action-plan_en Finance Sweden welcomes the initiative and the aim to gather insights and…

1 (3) The Swedish Bankers' Association's response to the European Commission’s proposal for changes in the regulatory framework for payment services Swedish Bankers’ Association welcomes the opportunity to provide the European Commission with its comments on the proposal for a Regulation of the European Parliament and of the Council on payment services in the internal market (PSR proposal).

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

The Swedish Bankers’ Association (SBA), Financial Benchmarks Sweden (FBS) and The Securities Dealers’ Association (SSDA) welcome the opportunity to provide comments on the EU Commission’s Inception Impact Assessment (Impact Assessment) for the review of Regulation (EU) 2016/1011 on indices used as benchmarks in financial instruments and financial contracts or to measure the performance of investment funds (BMR).

Finance Sweden welcomes the Commissions call for evidence on the targeted amendment regarding the prudential treatment of securities financing transactions under the Net Stable Funding Ratio (NSFR). The association concurs with the Commissions understanding of the issue and the proposed solutions.

The Swedish Bankers’ Association (SBA) welcomes the initiative from the European Commission regarding the review of the VAT rules for financial services and appreciates the opportunity to comment on the Roadmap/Inception Impact Assessment.

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.