European Association of Co-operative Banks (EACB)

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.

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 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 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.

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.

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.

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).