European Association of Co-operative Banks (EACB)

The EACB welcomes the Commissions objective to streamline and align elements of the EUs digital regulatory framework through the Digital Omnibus. For cooperative banks, highly regulated, data-intensive and subject to multiple overlapping frameworks, clarity, coherence and proportionality are essential to ensure that obligations remain workable without undermining consumer protection or security.

The EACB welcomes the Commissions intention to simplify elements of the AI Act through the AI Omnibus. For cooperative banks, the success of the AI framework depends on whether its requirements can be implemented in a predictable and operational way.

The EACB welcomes the opportunity to provide feedback on the EU Taxonomy screening criteria, and supports the continued simplification of reporting templates and the efforts to reduce unnecessary administrative burden for financial companies. The EU Taxonomy is a key instrument in financing the green transition, yet its application has proven to be complex and administratively burdensome in many respects.

The EACB welcomes the opportunity to provide feedback on the EU Taxonomy screening criteria, and supports the continued simplification of reporting templates and the efforts to reduce unnecessary administrative burden for financial companies. The EU Taxonomy is a key instrument in financing the green transition, yet its application has proven to be complex and administratively burdensome in many respects.

European Association of Co-operative Banks (EACB) welcomes the European Commissions efforts to revise the ESRS with the objective of creating a more targeted, proportionate and practical sustainability reporting framework under the CSRD.

The European Association of Co-operative Banks (EACB) recognises that the AI proposal is the Commission’s first ever legal framework on the matter, which addresses the risks of AI and aims to position Europe to play a leading role globally. It should be recognised that this is a risky bet.

The EACB supports the EC objectives: respect for human rights and the environment in line with the UN Agenda 2030 for Sustainable Development and the Paris Agreement on Climate Change. It is important to harmonize corporate sustainability due diligence at the EU level to ensure a level playing field and the spread of EU values. Including non-EU companies in the scope is vital.

Diversity of corporate models and governance ignored: The EY study differentiates between companies in different sectors, of different size and listed/ non-listed companies. Like the study the consultation document only refers to “companies” in the broadest sense and considers rolling out measures on all corporates.

The EACB welcomes the opportunity to provide comments on the proposed amendments and clarifications to the EU Taxonomy framework and appreciates the Commission's efforts to improve the clarity, usability and proportionality of the technical screening criteria and related reporting requirements.

The European Association of Cooperative Banks (EACB) welcomes the review of the Sustainable Finance Disclosure Regulation (SFDR) and supports the Commissions efforts to simplify the framework by reducing product level disclosures, removing certain obligations and streamlining reporting. These improvements are positive, yet several elements require clarification to ensure legal certainty and workable implementation.

The European Association of Co-operative Banks (EACB) welcomes the possibility to contribute to the discussion on the Data Act legislative proposal. We support the Commission’s general principle of facilitating the sharing of data. Sharing should be based on free choice, voluntary and on a contractual basis.

The European Association of Co-operative Banks (EACB), the voice of 3.135 co-operative banks in the EU, welcomes the opportunity to comment on the European Commission’s proposal for a “Regulation on the establishment of a framework to facilitate sustainable investment”.

The European Association of Co-operative Banks (EACB) is closely following the European Commission work on sustainable finance as this is a very important workstream for the EACB members due to the fact that co-operative banks, being local and regional banks, play a key role in sustainable financing.

The EACB considers the CSRD extremely important for the full achievement of the sustainable finance framework and welcomes many of the proposals. Our answer to the consultation represents our co-op banks members’ views as both users and preparers of sustainability reports. Please see below our comments.

The EACB welcomes the Commission initiative to amend the requirements in the Non-Financial Reporting Directive in order to ensure that investors and other interested parties have access to the information they need, while not imposing excessive reporting obligations on companies.

The EACB welcomes the launch of a call for evidence on Housing supply and affordability. We would like to emphasise the persistent supply-demand gap. Rising construction costs and higher interest rates continue to make access to housing more difficult, especially for first-time buyers and vulnerable households. For cooperative banks, this issue is a core priority.

The EACB welcomes the release of the Commission's Communication on the competitiveness of the EU Banking sector. We stress the importance of this holistic review of the prudential framework as current constraints of the EU regulatory framework have concrete repercussions on the real economy and the ability of the EU to face the significant challenges ahead.

The EACB welcomes the call for evidence on Competitiveness in the single banking market. This is a much needed step in the context of the roader efforts by the European Commission around simplification and competitiveness undertaken since 2025.

The European Association of Cooperative Banks (EACB) welcomes the opportunity to provide feedback on the European Commissions call for evidence concerning the simplification of EU rules on direct taxation. The EACB believes that tax policy should ensure legal certainty, proportionality and administrative simplicity for businesses.

The European Association of Co-operative Banks (EACB) welcomes the opportunity to provide its preliminary comments on a proposal for a Regulation on a Framework for Financial Data Access (FIDA) as part of the European Commissions 'Have your Say' consultation. This response aims to elaborate on the EACB's stance, emphasising key points of support and issues needing further consideration.

We welcome the EC’s data strategy and its commitment to creating a single market for data that will constitute a potential source of growth and innovation. Recognizing the leading role of the financial sector in the overall digital transformation of the economy, the EC’s ambition to promote data-driven innovation through an EU financial data space is also understood.

The fundamental problem of the implementation of the latest Basel standards resides in choices made at Basel level which make an adequate EU implementation challenging. The EACB acknowledges the Commission’s efforts to reduce the expected impact of reforms on the EU banking and credit markets and economy, while remaining compliant with the spirit of the global agreement, but further efforts are necessary.

The European Association of Co-operative Banks (EACB) welcomes the opportunity to comment on the European Commissions legislative proposal for a Council Directive on Business in Europe: Framework for income Taxation (BEFIT). The EACB would welcome an actual decrease of compliance burden.

We appreciate that in the current proposal for a Directive, Article 272(1)(c) of VAT Directive 2006/112/EC exempting taxable persons carrying out only supplies of goods or of services remains unchanged. However, for the financial sector the proposal could be optimised by amending Article 272(1)(c) in such a manner that: - it is not an option for Member States but rather a mandatory exclusion; - it does also apply to…

The European Association of Co-operative Banks (EACB) is the voice of the co-operative banks in Europe. It represents, promotes and defends the common interests of its 28 member institutions and of co-operative banks in general. Co-operative banks form decentralised networks which are subject to banking as well as co-operative legislation.

The European Association of Co-operative Banks (EACB) would like to stress that implementing a standardised EU-wide system of withholding tax (WHT) relief at source would be the best option as it can be implemented in the most resource-efficient way from the banks' perspective.

The members of the European Association of Co-operative Banks (EACB) gladly take the opportunity to comment on the European Commission’s roadmap consultation “New EU system for the avoidance of double taxation and prevention of tax abuse in the field of withholding taxes”.

The European Association of Co-operative Banks (EACB) represents, promotes and defends the common interests of its 27 member institutions and of cooperative banks, with regard to banking as well as to co-operative legislation. Please find the EACB feedback on this consultation in the attached PDF document. Thank you for your attention.

The members of the European Association of Cooperative Banks (EACB) would like to hereby share their view on the European Commission’s inception impact assessment of the CCD review. Generally speaking, we believe that regulatory stability is of paramount importance considering the circumstances that banks are currently facing.

The European Association of Co-operative Banks (EACB) welcomes the opportunity to provide feedback on the European Commission's proposals for a Payment Services Regulation (PSR) and Payment Services Directive (PSD3). The EACB actively contributed to the PSD2 review process with our input reflecting the views of cooperative banks across the EU.

We appreciate the EC efforts in tackling the enforcement of the right to equal pay, but we have concerns that current proposals do not sufficiently reflect factual and legal reality, and may excessively overburden employers. The EC’s assumption of a gender pay gap in the EU of 14% seems excessive.

The members of the EACB gladly take the opportunity to comment on the European Commission’s proposal for a directive on laying down rules on a Debt-Equity Bias Reduction Allowance (DEBRA) and on limiting the deductibility of interest for corporate income tax (CIT) purposes. The EACB appreciates the fact that credit institutions - as defined in Art.

The European Association of Co-operative Banks (EACB) welcomes the opportunity to comment on the European Commission's call for evidence on the recast of EU rules on administrative cooperation in the field of taxation (DAC). On DAC consolidated text: In our opinion, consolidating DAC 1 to 9 does not address the objective of reducing administrative burdens. DAC 1 to 9 have already been transposed into national law.

The EACB welcomes the opportunity to participate in the Commissions call for evidence on mortgage portfolio standards under the Energy Performance of Buildings Directive. As the voice of the cooperative banking sector in the EU, we actively followed the work of the institutions in shaping the EPBD, arguing in favour of a voluntary framework.

Goal of harmonisation The focus of harmonisation of insolvency laws should be to contribute to the greater economic process. Important (sub) goals grounded in notions of (distributive) justice held within different member states (rights of workers, the environment etc.) should be also reflected. These sub-goals may vary from member state to member state.

The European Association of Co-operative Banks (EACB) welcomes the possibility to contribute to the discussion on the proposal for a Directive on adapting non-contractual civil liability rules to artificial intelligence (the AI Liability Directive). Please find our position on this proposal in the attached document.

The European Association of Cooperative Banks (EACB) gladly takes the opportunity to comment on EC roadmap consultation on the taxation of the digital economy following its comments on the OECD Pillar I and II consultations on the same issue. The EACB welcomes the EC plans on the taxation of the digital Economy.

The EACB welcomes this opportunity to provide feedback to the European Commission's proposal to amend the EU Benchmarks Regulation (BMR). We understand that the proposed Delegated Act is a sort of quick fix solution, which is important due to current critical events such as the cessation of LIBOR without an adequate replacement and the COVID-19 pandemic.

We welcome the Commissions proposed amendment to the LCR Delegated Act increasing the eligibility of senior tranches of STS traditional securitisations with credit quality CQS5 to CQS7as a first step in shifting away from the current treatment, which results overly conservative and deeply affects the market liquidity of those securities, in turn impacting their price and issuance volume, ultimately discouraging…

The European Association of Co-operative Banks (EACB) supports the European Commission (EC) initiative to make permanent the current transitory prudential treatment for secured funding transactions (SFT) and unsecured transactions with a residual maturity of less than six months with financial customers, for the purpose of the Net Stable Funding Requirement (NSFR).

The EACB appreciates the technology neutrality of the DMFSD, which has allowed banks to develop and adapt distance marketing to different channels, reflecting new technologies and consumer expectations. Neutrality avoids the need to consistently adapt legislation. Specifying in the legislation how to adapt the information to different devices would not be technology neutral or scalable.

With regard to the practical impact, the EACB asks the Commission to clarify: • treatment of deferred taxes, given that - for purpose of determining turnover, taxes and the tax base - covered taxes include not only local taxes on income and earnings, but also complex corrections for deferred taxes (Articles 19-21); • considering that the effective tax rates (ETR) are derived based on the country-by-country reports…

The EACB welcomes the modernization of the VAT treatment of financial services as the existing regulations are out-of-date and do no longer reflect current practices in the financial sector. The current situation leads to legal uncertainty and an unbalanced level playing field and thus a lack of neutrality.

General comments Depositor confidence is a public good built up hard for decades by relevant national schemes, including private schemes. Harmonization should be sought but not pose downside effects. In view of the upcoming consultation and next steps, the value of existing crisis management tools must be assessed and reflected.