Feedback from the Swedish Securities Markets Association on the CSDD The Swedish Securities Markets Association (SSMA) is an industry association founded in 1908 and representing the interests of 24 banks, investment banks and investment firms active in Swedish securities markets.
SSM
Swedish Securities Markets Association
Industry association · Sweden · EU Transparency Register 7777147632-40
6
positions filed
in the 665 files tracked
6
legislative files
of 665 tracked
6
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 665 consultation files tracked so far (57,774 submissions, mostly 2021–26), so an organization's real filing history is larger, not smaller.
Who they are
Among the 1518 trade and business associations on this site, they rank #595 by legislative files engaged, a count of participation, not a measure of influence.
1
declared lobbying FTE
self-declared
€50K+
declared costs / yr (floor)
2
EP accreditations
as declared to the register
2008
in the register since
Declares membership of
- EFSA, European Forum for Securities Associations https://efsa-securities.eu
- ICSA, International Council of Securities Associations https://icsa.global/
- NSA, Nordic Securities Association https://nsa-securities.eu/
- EBF, European Banking Federation https://www.ebf.eu/
Self-declared to the EU Transparency Register (snapshot 14 Oct 2026).
- Register category
- Trade and business associations
- Registered as
- Swedish Securities Markets Association (Swedish: Föreningen Svensk Värdepappersmarknad) (SSMA (Swedish: SVPM))
- Head office
- Stockholm, Sweden
Self-declared to the EU Transparency Register (snapshot 14 Oct 2026); cost bands are floors, not audited totals. Reused under Commission Decision 2011/833/EU.
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Their record over time
Swedish Securities Markets Association filed 6 positions between 6 May 2022 and 25 Mar 2026, across 6 of the 665 legislative files tracked here, attaching a full position paper 6 times.
2022 · 2 filed2023 · 2 filed2026 · 2 filed
What they argued
In December 2025 the European Commission published the Market Integration and Supervision Package (MISP). The Swedish Securities Markets Association (SSMA) welcomes the European Commissions ambition to strengthen EU capital markets and supports the overarching goals of market integration and increased competitiveness but would like to emphasise that well-functioning local ecosystems remain crucial.
The Swedish Securities Markets Association (SSMA) notes the importance of Providers being resourced to interact with users of ESG ratings as well as the companies being rated. It may be difficult to establish contact with analysts at Providers when published information is factually incorrect, a problem made worse where Providers are not acquainted with the way societies in the EU or in a particular EU country…
SSMA’s comments focus on CSDR article 7 and the delegated regulation (EU) 2018/1229 (the RTS). We are of the opinion that penalties is a better tool for addressing settlement fails than mandatory buy-ins (MBI) and would therefore recommend a removal of the overall MBI provisions.
The Swedish Securities Markets Association (SSMA) welcomes the opportunity to comment on the European Commissions proposal for amendments of EMIR, published on December7th. Below is a summary of our key concerns and observations, more detailed comments can be found in the attached document. - The SSMA does not support the proposal on active accounts and think it is a forced relocation policy.
The Swedish Securities Markets Association (SSMA) welcomes the European Commissions Market Integration and Supervision Package (MISP) and supports the overarching goals of market integration and increased competitiveness but would like to emphasise that well-functioning local ecosystems remain crucial.
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Turns up on the same files
Organizations that also filed on at least two of the same consultations. A shared interest in the same dossiers, not evidence of coordination, and we do not suggest any.
Showing 5 of 59.
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Quotes are verbatim from submissions published by the European Commission, trimmed to their opening passage and never summarized by a model. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.