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Asociación Española de Banca

AEB

The Spanish Banking Association represents banks in policy discussions with Spanish and EU authorities.

Lobbying Activity

Meeting with Nicolo Brignoli (Cabinet of Commissioner Valdis Dombrovskis)

27 Jan 2026 · Simplification, financial services

Meeting with Kurt Vandenberghe (Director-General Climate Action)

27 Jan 2026 · Sustainable Finance; Banking Supervision; Climate Policy; Simplification

Meeting with Alberto De Gregorio (Director-General Legal Service)

19 Jan 2026 · Visit of Alexandra Kindelan

Meeting with Giovanni Crosetto (Member of the European Parliament, Shadow rapporteur) and Fédération bancaire française and

5 Nov 2025 · Securitisation Framework

Meeting with René Repasi (Member of the European Parliament, Rapporteur)

15 Oct 2025 · Payment Services Proposals

Meeting with Ralf Seekatz (Member of the European Parliament, Rapporteur) and Association for Financial Markets in Europe and Schroders Investment Management (Europe) SA

1 Oct 2025 · Verbriefung

Meeting with Jonás Fernández (Member of the European Parliament) and BANCO BILBAO VIZCAYA ARGENTARIA and Federation of European Securities Exchanges

18 Sept 2025 · Saving and Investment Union and sectorial priorities

Spanish banking industry seeks lighter securitisation liquidity rules

15 Jul 2025
Topic — Review of the treatment of securitisations under the Liquidity Coverage Ratio.
Message — The association requests that eligibility tests occur only at the start. They also propose lower discount rates to encourage bank investment. The group suggests better asset classification to bypass existing investment caps.123
Why — Removing regulatory caps would allow banks to increase their investment volumes.45
Impact — Other liquid investments lose market share as banks prioritize these assets.6
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Spanish Banking Association Urges Tax Incentives for Investment Accounts

8 Jul 2025
Topic — Consultation on creating a European blueprint for savings and investment accounts for retail investors.
Message — The AEB advocates for significant tax incentives and a simplified regulatory framework to encourage retail investing. They recommend reducing disclosure burdens and including diverse financial products like pension funds.12
Why — Banks would reduce costs by using existing systems and lowering their risk of tax-related legal issues.34
Impact — Member States may see lower tax revenues if they adopt the proposed favorable tax regimes.5
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Meeting with Tatyana Panova (Head of Unit Financial Stability, Financial Services and Capital Markets Union) and Banco Santander, S.A.

5 Jun 2025 · Discussion on the state of play of European equity markets

Spanish banking group urges EU to simplify sustainability reporting

29 May 2025
Topic — This consultation reviews EU rules for sustainability-related disclosures within the financial services sector.
Message — The group requests removing redundant reporting requirements that overlap with other European transparency laws. They propose a common product classification system to help investors understand different investment types. They also suggest simplifying templates to make sustainability information clearer and less repetitive.123
Why — Simplified rules would reduce the high administrative burden and compliance costs for financial institutions.4
Impact — Third-party data providers may lose revenue if banks stop purchasing data for redundant reporting.5
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Meeting with Maria Luís Albuquerque (Commissioner) and

27 May 2025 · • SIU • simplification

Meeting with Alicia Homs Ginel (Member of the European Parliament)

14 May 2025 · Prioridades de la Comisión Especial HOUS

Meeting with Borja Giménez Larraz (Member of the European Parliament, Rapporteur)

14 May 2025 · Housing crisis in the European Union

Meeting with Jorge Martín Frías (Member of the European Parliament, Rapporteur)

7 May 2025 · Securitization and INI SMES and scale-ups financing

Meeting with Raúl De La Hoz Quintano (Member of the European Parliament)

23 Apr 2025 · Omnibus

Spanish Banking Association urges removal of Green Asset Ratio

26 Mar 2025
Topic — Initiative to simplify EU sustainability reporting and technical screening criteria for companies.
Message — The association demands the removal of the Green Asset Ratio as a mandatory metric. They also seek to exempt retail loans from environmental checks and delete several reporting templates.123
Why — Streamlining these requirements would significantly lower operational costs and improve the sector's competitiveness.4
Impact — Environmental groups lose a standardized tool for monitoring the sustainability of bank lending portfolios.5
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Meeting with Daniel Calleja Crespo (Director-General Legal Service) and

19 Mar 2025 · Spanish and EU bank industry and financial service regulation

Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union) and

19 Mar 2025 · Financial services policy, SIU and Basel

Meeting with Jorge Buxadé Villalba (Member of the European Parliament)

19 Mar 2025 · Euro digital

Meeting with Jonás Fernández (Member of the European Parliament)

19 Mar 2025 · Saving and Investment Union, digital euro and economic priorities

Meeting with Aurore Lalucq (Member of the European Parliament)

19 Mar 2025 · Priorities of the EU legislature for the banking sector

Meeting with Damian Boeselager (Member of the European Parliament, Shadow rapporteur)

19 Mar 2025 · Digital Euro

Meeting with Didier Millerot (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

18 Mar 2025 · Exchange of views on the Omnibus Proposal

Spanish Banking Association seeks permanent relief for repo transactions

10 Mar 2025
Topic — A consultation on amending EU bank rules for treating certain short-term securities financing.
Message — The association calls for making current temporary rules permanent to avoid stricter global standards. This supports market-making and the efficient management of security inventories.12
Why — Maintaining these rules prevents increased funding costs and ensures a global level playing field.34
Impact — Sovereign bond markets suffer from reduced liquidity and less attractive trading conditions.56
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Response to Savings and Investments Union

6 Mar 2025

SIUI will facilitate access to financing for corporates and SMEs, improve opportunities for savers, and strengthen the financial stability of the European Union. However, it will not be a quick process and requires measures in various areas, both at EU and at Member State level The Banking Union, which could become a good example of free flow of capital and funding, would enhance the integration of the SIU. The lack of an EDIS to mutualize losses in the event of a banking crisis is one of the most relevant sources of fragmentation in the European financial market. Financial stability and depositor protection are key for any investment union, so developing an EDIS and a powerful liquidity in resolution framework should be a priority Challenges of the SIU have to be be addressed through ambitious advances in developing new and harmonized fiscal incentives for investment products and the development of pension schemes that provide long term and tax efficient investment opportunities. Without this aspect, the European project in capital markets will hardly land on real terms Participation in private pension systems should be encouraged. This will not only improve the financial security of retirees but also stimulate broader investment in the capital markets, contributing to economic growth and market stability Simplification for investors and issuers of the requirements for issuing, investing and participating in the market is strongly encouraged as a means to create a simpler and more attractive access for retail participation (i.e. tax reporting, which in some countries is very burdensome for retail investors and the reason many savers do not invest) The existing RIS should be reassessed to streamline procedures, reduce administrative burdens, ensure that retail investors can access expert advice, as well as high-quality services, and a wide range of investment products without being hindered by regulatory complexity. If not, this reform could add unnecessary complexity to the current regulatory framework, with negative impacts on entities, clients, and ultimately on the financing of the European economy New financial products are not necessary as the current market already offers sufficient opportunities. There are already other European products with a similar function (ELTIFs, PEPPs) that have not so far proven to be effective in attracting the savings of European citizens, due to the existence of caps and no incentives. Said that, the possibility of designing a savings form with a significant fiscal incentive component is an interesting initiative A number of drivers are moving liquidity out of EU capital markets. Among them: the EU market structure has become too complex and costly; excessive regulation and supervision, which are not coherent with market reality; and a growing inequality in access to liquidity. We are calling for more transparent markets, where market participants can operate on a level playing field. Liquidity should be accessible to everyone and on the same conditions. We encourage authorities, post MiFIR Review, to closely monitor the quality and availability of liquidity in EU shares, so as to make sure that future development of the regulatory framework is based on a deep understanding of market mechanisms Banks could be significant investors in the capital SMEs and corporates, if the current Basel III framework, which heavily penalizes equity investments in other entities, were reviewed. In addition, securitisation can play a crucial role in the development of the SIU, but some improvements to the regulatory and supervisory frameworks are needed. These include the reduction of capital requirements for banks and insurance companies, the adjustment of liquidity regulations and a significant reduction in transparency and due diligence requirements Finally, harmonized supervisory practices are crucial for consistency, efficiency, and competitiveness in EU financial markets
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Meeting with Mirzha De Manuel (Cabinet of Commissioner Valdis Dombrovskis), Nicolo Brignoli (Cabinet of Commissioner Valdis Dombrovskis)

5 Mar 2025 · Omnibus, digital euro

Meeting with Elena Arveras (Cabinet of Commissioner Maria Luís Albuquerque)

11 Feb 2025 · Sustainability Omnibus

Meeting with Jonás Fernández (Member of the European Parliament)

5 Feb 2025 · Economic priorities & Digital Euro

Meeting with Mattias Levin (Acting Head of Unit Financial Stability, Financial Services and Capital Markets Union) and Banco Santander, S.A. and BANCO DE SABADELL, S.A.

5 Feb 2025 · Digital Euro

Meeting with Jonás Fernández (Member of the European Parliament)

26 Sept 2024 · Banking Union - Economic priorities

Meeting with Fernando Navarrete Rojas (Member of the European Parliament) and American Express Corporation

12 Sept 2024 · EUROFI

Meeting with Isabel Benjumea Benjumea (Member of the European Parliament)

18 Jul 2024 · Reunión sector bancario

Meeting with Pablo Arias Echeverría (Member of the European Parliament)

18 Jul 2024 · Challenges and opportunities for the financial sector and banking priorities in the new EU term

Meeting with Jonás Fernández (Member of the European Parliament)

18 Apr 2024 · Legislative priorities 24-29

Meeting with Gilles Boyer (Member of the European Parliament, Shadow rapporteur)

28 Nov 2023 · Digital euro

Meeting with José Manuel García-Margallo Y Marfil (Member of the European Parliament)

24 Nov 2023 · PSD3 and PSR1

Spanish Banking Association demands data sharing reciprocity across all sectors

31 Oct 2023
Topic — EU consultation on a new framework for sharing financial and non-financial data.
Message — AEB proposes that the framework "should not impose new data sharing obligations" on banks. They want a "level playing field" where all participants share data reciprocally.12
Why — Banks would protect their internal expertise while gaining access to non-financial data pools.34
Impact — Non-financial firms lose the benefit of "asymmetric access" to data without providing reciprocity.56
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Response to Payment services – revision of EU rules (new Regulation)

30 Oct 2023

The Spanish Banking Association (AEB) welcomes the importance assigned to fraud in the proposal of Payment Services Regulation. It enhances the need to prevent fraud (PSPs are very concern about it and take most and probably more measures than those prescribed). However, it still lacks effective measures for PSPs to do more and there is room for improvement if we want a safe, robust payments market industry & future-proof. There is a clear opportunity for the EU co-legislators to improve the proposal during the legislative process. The proposed Regulation needs to be reinforced to protect the whole system against fraud, not only with security measures, transaction monitoring and awareness obligations, but with additional preventive measures (more information to be shared amongst PSPs) and legal dispositions to allow PSPs the freeze and recovery of funds once a fraud is identified. This in order to protect the users and prevent the systems to be abused by criminals regardless the country of origin and destination of the involved funds. Fraud needs to be stopped; it is not about who pays at the other end. Consumer protection measures should not provide a refuge for criminals. Following items on attached file: - Mandatory refund obligation under certain conditions for Payment Service Providers in case of impersonation fraud - Obligation for PSPs to have transaction monitoring in place and allowing for fraud data sharing - Reactive measures in front of fraud for remediation - Extending the mandatory IBAN-name check for all credit transfers - Changes in SCA - Access to cash in the proposed Directive (PSD3) that accompanies the PSR - Transparency obligations - Open Banking Contingency option - Open Banking Lack of compensation for providing access to customers data - Open banking The PSR should be integrated within the broader FIDA framework - Permission dashboards - Open Banking Functionalities and standards - Payment Systems - Enforcement and implementation - Application
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Response to Establishing the digital euro

8 Sept 2023

We thank the opportunity to provide its feedback to the European Commission on the Proposal for a Regulation on the establishment of the digital euro, released on the 28th of June 2023. We welcome the European Commissions efforts to balance relevant policy objectives and try to limit the potential negative impact on the eurozone economy and financial system. In line with our June 2022 submission to the European Commissions targeted consultation on a digital euro, we are of the view that preserving financial stability and the ability of the banking sector to support the real economy should be an absolute priority in the design of a possible digital euro. There are yet too many unanswered questions around the need and the value-added of a digital euro for citizens and merchants compared to existing payment solutions that require a comprehensive debate at political level, alongside the negotiation of the legislative proposal. Thus, we support a prudent approach by the authorities to thoroughly evaluate the challenges and implications of its possible issuance and implementation Please find attached our preliminary comments on the most relevant issues of the proposal, identified in a initial assessment.
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Response to Banking Union: Review of the bank crisis management and deposit insurance framework (DGSD review)

30 Aug 2023

Introduction. We fully support the BU. In this sense, we think that there is still room for improvement on the resolution framework, and this proposal goes in the right direction. However, we think that it is key to reach an agreement on the third pillar (EDIS). We are distinct countries with different situations, but if we want to have a real single European market, we need to leave our differences aside and think about what Europe can mean and become. For the time being, the resolution framework has barely been used; Since 2015, most of the crises in Europe have involved small or medium-sized institutions, and the resolution framework has not been applied. On the other hand, public funds have been used in many of these crises, which is contrary to the framework itself and the spirit of the rule. We believe the framework should be improved in order to allow that those banks are dealt within the resolution framework to ensure a more efficient market exit and avoid any limbo situations or resolution solutions based on bail-out. - We think that the European authorities should address the sooner the better the lack of a fully-fledged EDIS. The lack of an EDIS is a great source of fragmentation which means that in the case of a financial crisis, those solvent banks might not have access to the capital markets to raise capital or liquidity because their sovereign´s fiscal position is weak. A European deposit guarantee fund that assures a homogeneous protection to all European depositors and helps to break the link between banks and their sovereigns is essential before another financial crisis breaks out. Contrary to the optimism of the authorities, we believe that this proposal does not advance on EDIS but just focuses on improving the resolution framework for medium and small-sized institutions. In our view, the proposal creates more fragmentation and reinforces the link between the state and the firm. - One of the lessons we have learned from the last crises in the US and Switzerland is that authorities need to have at their disposal a complete resolution toolkit to solve such crises. US and Swiss authorities have avoided the contagion to other entities thanks to their central bank, who can work as a lender of last resort in resolution. Unfortunately, we do not have some of these tools in the EU. We are missing a liquidity in resolution tool. We believe that it is necessary to provide the European institutional framework for crisis management with a public liquidity tool in resolution that grants enough liquidity and gives trust into the system to cope with a systemic crisis or a globally systemic entity crisis. Liquidity is the reason why entities become failing or likely to fail in most of the cases. Under the current environment (social networks and new digital platforms) it seems impossible to block severe bank runs without a credible and very large liquidity tool in resolution. - We are also missing the harmonization of the national insolvency proceedings frameworks. We acknowledge that this reform is complex since there are many agents who might be involved and there are a lot of national interests. However, we are of the view that this harmonization could simplify the EU framework and the resolution processes of cross-border institutions, improve the level playing field, ease the public interest assessment and the no-creditworse-off test undertaken by the Single Resolution Board. - The revision of the state aid framework and its harmonization across Europe is also important to ensure a level playing field in the EU banking industry. - We think that the sale of business tool is the most credible tool in the resolution framework. The few cases that the resolution framework has been used in the EU has ended up with the sale of the resolution entity. In this sense, we think that the regulatory framework should find ways to make the resolution procedure appealing for potential buyers.
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Response to Retail Investment Package

3 Aug 2023

Spanish Banking Association (AEB) welcomes the opportunity to comment on the Proposal for a Directive of the European Parliament and of the Council amending Directives (EU) 2009/65/EC, 2009/138/EC, 2011/61/EU, 2014/65/EU and (EU) 2016/97 as regards the union retail investor protection rules and the Proposal for a Regulation of the European Parliament and of the Council amending Regulation (EU) 1286/2014 as regards the modernisation of the key information document. Please find attached our feedback.
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Meeting with Gerassimos Thomas (Director-General Taxation and Customs Union)

4 Jul 2023 · Physical meeting - OECD Two-Pillar Approach and the taxation of the financial sector

Meeting with Jonás Fernández (Member of the European Parliament, Rapporteur) and Banco Santander, S.A. and BANCO BILBAO VIZCAYA ARGENTARIA

27 Apr 2023 · EU Banking Package 2021

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness) and Banco Santander, S.A. and BANCO BILBAO VIZCAYA ARGENTARIA

27 Apr 2023 · digital euro (with Cab Dombrovskis)

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis) and Banco Santander, S.A. and BANCO BILBAO VIZCAYA ARGENTARIA

27 Apr 2023 · Digital Euro

Meeting with Ernest Urtasun (Member of the European Parliament)

25 Apr 2023 · ECON issues.

Meeting with Jonás Fernández (Member of the European Parliament)

25 Apr 2023 · Digital euro

Meeting with Jonás Fernández (Member of the European Parliament) and Bizum

28 Mar 2023 · Instant payments in euro

Meeting with Agnieszka Drzewoska (Cabinet of Commissioner Mairead Mcguinness) and Banco Santander, S.A. and BANCO BILBAO VIZCAYA ARGENTARIA

14 Feb 2023 · Retail investment strategy. ETFs.

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis) and Banco Santander, S.A. and BANCO BILBAO VIZCAYA ARGENTARIA

14 Feb 2023 · Retail investment strategy

Meeting with Agnieszka Drzewoska (Cabinet of Commissioner Mairead Mcguinness) and Banco Santander, S.A. and

1 Feb 2023 · Retail Investment Strategy

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis) and Banco Santander, S.A. and

1 Feb 2023 · retail investment strategy

Response to Instant Payments

4 Jan 2023

The Spanish Banking Association (AEB in its acronym) welcomes the opportunity to provide comments in the context of the public participation process on the Regulation amending the SEPA Regulation and the Regulation on cross-border payments as regards instant credit transfers. In line with the review, the AEB has analysed the text of the proposal and the content of the regulation, and the main comments are included in the attached file.
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Meeting with Adriana Maldonado López (Member of the European Parliament) and Apple Inc.

16 Nov 2022 · Transcurso de informes legislativos en IMCO

Meeting with Pelayo Castro (Cabinet of High Representative Josep Borrell Fontelles) and Banco Santander, S.A. and BANCO BILBAO VIZCAYA ARGENTARIA

19 Oct 2022 · Latin America, digitalization, artificial intelligence and data protection.

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis)

29 Sept 2022 · Digital & open finance

Meeting with Ana Gallego (Director-General Justice and Consumers)

28 Sept 2022 · Challenges in the banking sector

Meeting with Nathalie De Basaldua (Cabinet of Commissioner Mairead Mcguinness), Tommy De Temmerman (Cabinet of Commissioner Mairead Mcguinness)

28 Sept 2022 · Basel, digital euro

Meeting with Pierre-Arnaud Proux (Cabinet of Executive Vice-President Margrethe Vestager), Stina Soewarta (Cabinet of Executive Vice-President Margrethe Vestager)

28 Sept 2022 · Digital policies, artificial intelligence and data economy.

Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

28 Sept 2022 · Basel implementation and open finance

Response to Open finance framework

2 Aug 2022

Find attached our comments
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Meeting with Isabel Benjumea Benjumea (Member of the European Parliament)

5 Jul 2022 · Basilea III

Meeting with Jonás Fernández (Member of the European Parliament, Rapporteur) and Association for Financial Markets in Europe

23 May 2022 · EU Banking Package 2021 - "Basel III rules" panel discussion

Spanish Banking Association urges broader data sharing scope

11 May 2022
Topic — The Data Act establishes rules for fair data access and use across different sectors.
Message — The association requests excluding banking hardware like ATMs from the scope while broadening the regulation to include telco and utility data. They also emphasize that data holders must receive fair compensation to prevent market asymmetries.123
Why — Banks would gain access to diverse datasets to improve credit assessments and financial service offerings.4
Impact — Telecoms and utility companies lose exclusive control over consumer data that banks wish to access.5
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Meeting with Jonás Fernández (Member of the European Parliament, Rapporteur)

5 May 2022 · EU Banking Package 2021

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis)

21 Apr 2022 · Basel III implementation

Meeting with Tommy De Temmerman (Cabinet of Commissioner Mairead Mcguinness)

31 Mar 2022 · Basel III

Meeting with Jonás Fernández (Member of the European Parliament, Rapporteur)

24 Feb 2022 · EU Banking Package

Response to Alignment EU rules on capital requirements to international standards (prudential requirements and market discipline)

23 Feb 2022

The Spanish Banking Association (AEB) welcomes the European Commission proposal for the EU transposition of the “Basel III: Finalizing post-crisis reform” standard. AEB acknowledge the efforts made by the EU regulators to achieve several goals such as: - Reducing the impact in terms of capital requirement which will foster the efficiency of the EU banking sector. It is important to highlight that capital increases have a direct impact on lending volumes or lending prices. Reducing the impact in capital requirements will grant stability in volumes and prices. - Considering EU specificities which will ease the access to financial resources for EU corporates. Having a good understanding on these EU specificities will create a proper environment for corporates to finance their businesses. - Balancing between risk sensitiveness and simplicity which will reduce the regulatory burden for the European banks and will enhance comparability of capital ratios while setting a risk-sensitive prudential framework. We are of the view that the proposal, is balanced and addresses some of the key concerns raised by Member States and banks with different business models. In particular, we positively welcome the following measures that have been included in the legal package: - Operational risk: We fully support the EC proposal as regards of disregarding past operational risk losses setting the capital calculation in terms of the Business Indicator Component, using a national discretion granted by the Basel Committee. These are good news since past losses are not good predictors of future losses and do not reflect the entities’ risk profile. - We welcome the proposed treatment for equity intragroup holdings, which helps recognizing the banking model based on subsidiaries. We also welcome other measures that smooth the impact of the new equity treatment, stimulating the financing of the economy through equity - The maintenance of the EU specificities: The SME and infrastructure supporting factors, and the CVA exemption, are important measures for banks to support the financing and hedging of risks of EU businesses in an economy where banks provide 75% of their external funding - The transitional provisions that postpone the application of a 10% CCFs on the Unconditionally Cancellable Commitments (UCC) to 2033, however we consider other measures could have a very negative impact on trade finance in the EU and therefore need to be reviewed. However, we think there is room for further improvement to recognize the reality of the EU banking sector and for this reason we would like to comment on some specific elements. Proposal for further improvements to the CRR3/ CRD6 package
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Meeting with Jonás Fernández (Member of the European Parliament, Rapporteur)

15 Dec 2021 · EU Banking Package 2021

Meeting with Tommy De Temmerman (Cabinet of Commissioner Mairead Mcguinness) and Banco Santander, S.A. and BANCO BILBAO VIZCAYA ARGENTARIA

20 Oct 2021 · Basel III (The meeting was shared with the Cabinet Dombrovskis)

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis) and Banco Santander, S.A. and BANCO BILBAO VIZCAYA ARGENTARIA

20 Oct 2021 · Basel III

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis), Mirzha De Manuel (Cabinet of Executive Vice-President Valdis Dombrovskis) and Banco Santander, S.A.

18 Oct 2021 · Basel III implementation

Meeting with Valeria Miceli (Cabinet of President Ursula von der Leyen)

14 Oct 2021 · Basel III

Response to Quick Fix to the UCITS Directive

9 Sept 2021

SPANISH BANKING ASSOCIATION COMMENTS on Proposal for a directive of the European Parliament and of the Council amending Directive 2009/65/EC as regards the use of key information documents by management companies of undertakings for collective investment in transferable securities We are thankful for the opportunity to provide feedback on the proposal for a directive of the European Parliament and of the Council amending Directive 2009/65/EC as regards the use of key information documents by management companies of undertakings for collective investment in transferable securities (UCITS). Our main comments on the proposal are: 1- It is of crucial importance that it is clearly stated that the UCITS KIID is to be replaced in its entirety by the PRIIPS KID. We believe that the proposal for a Directive amending UCITS should cover all the aspects to consider that the PRIIPS KID meets the requirements of Directive 2009/65/EC in terms of the key investor information document: publication, updating, availability, etc. However, the actual wording is configured in such a way that the issuance of a PRIIPS KID may be optional for the management company or, where applicable, the investment company and therefore not mandatory: "(...) where an investment company or, for any of the common funds it manages, a management company draws up, provides, revises and translates a key information document which complies with the requirements for key information documents laid down in Regulation (EU) No 1286/2014 (...)". This could result in the management company or the investment firm not publishing a PRIIPS KID and ending up publishing a KIID as set out in Regulation (EU) 583/2010 and therefore also compliant with Directive 2009/65/EC. This situation could happen if the UCITS CIS is not intended for clients classified as retail and the management company or, where applicable, the investment company is not obliged to publish a PRIIPS KID (in accordance with Regulation (EU) 1286/2014). As a consequence, although it would avoid duplication in the provision of key information documents prior to contracting (if the client is not classified as retail, the provision of a PRIIPS KID would not be mandatory), it does not imply a 'total' replacement of the UCITS KIID by the PRIIPS KID. In short, we would ask that the wording of the proposal for a Directive amending UCITS should complete the 'full' replacement of the UCITS KIID by the PRIIPS KID in all scenarios, including for UCITS IICs purchased by clients not classified as retail clients. 2- Harmonisation on the date of application. The amendments provided for in the UCITS Amendment Directive accompany those introduced by the "PRIIPS Amendment Regulation and the "PRIIPS RTS Amendment Delegated Regulation". As, during the consultation on the PRIIPS Amendment Regulation, a request has been made to extend the implementation period by one year from its entry into force (in order to make the necessary changes), the requests should be aligned. 3- Concern with its transposition and its alignment with the rest of the rules. The proposed Directive amending UCITS needs to be transposed into national law by 30 June 2022 (in any case, it should be applicable from 1 July 2022). It is necessary to bear in mind the amendments that the legislator may introduce in this respect in the national UCITs rules. In this regard, in the Spanish case, in the Preliminary Draft Bill amending the UCITs Law and the Draft Royal Decree amending the UCITs regulation (both published in June this year), a 'total' replacement of the UCITS KIID by the PRIIPS KID is proposed.
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Response to Quick fix to the PRIIPs Regulation

9 Sept 2021

See attached file
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Response to Designation of a statutory replacement rate for CHF LIBOR (Benchmarks)

31 Aug 2021

Please find attached the Spanish Banking Association's response to the consultation on the statutory replacement rate for Swiss Franc LIBOR (CHF LIBOR)
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Response to Designation of a statutory replacement rate for EONIA (Benchmark)

31 Aug 2021

Please find attached the Spanish Banking Association's response to the consultation on the Statutory replacement rate for the EONIA benchmark.
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Meeting with Michael Hager (Cabinet of Executive Vice-President Valdis Dombrovskis) and Fédération bancaire française and

28 Jun 2021 · Basel III

Response to Retail Investment Strategy

18 May 2021

See document attached
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Response to Instant Payments

7 Apr 2021

The Impact Assessment establishes several objectives: "making cross-border payments easier, faster and cheaper", "ensuring citizens and companies have high quality, secure and cost-efficient payment solutions to make all their payments, both domestically and cross-border”, "reduce fragmentation in the internal market, sovereignty in payment solutions". These objectives should be considered broadly and not focus solely on the domain of instant payments. Two layers should be clearly differentiated: the payment schemes (inter PSPs space) and the customer services or final solutions. The last may have some competition concerns but require standardisation and interoperability arrangements, or a regulatory framework for the payment services to reach the intended outlined objectives. Nevertheless, those standardisation efforts should be led by market forces, only this will ensure a wider support and a faster adoption of any standard without disrupting the market. The lines between different payment solutions, are becoming blurred; the need for a customer to know the underlying payment scheme is less relevant. It would be more useful for the authorities to establish clear regulations that allow the provision all payment services independently of the underlying payment schemes to be used. The Impact Assessment remarks the importance for customers to know what type of payment is being used in the services provided so they can choose the cheapest but actually, what is relevant for the customers is to know the conditions (speed, user experience, refund possibilities, credit facilities etc.) including the cost of each service, to decide what is more convenient. Concerning the policy options for the EC, it is preferable to have non-regulatory approaches that promote soft-touch regulation, guidance to the market, and cooperation among authorities and market players. • It is essential to avoid introducing new regulations to impose specific solutions and change market conditions causing uncertainty, since innovative and convenient payments solutions will only emerge if they are based on stable business models and respond to market expectations. • Regulatory certainty and stability on the payments market, including sustainable business models, are needed. EC should support market players in their definition to ensure compliance with EU payment regulations and competition rules. • EC monitoring of market evolution and assessment of the effects of voluntary efforts is welcomed. • The idea of establishing specific requirements as fixed prices for payments, might be failing to consider that PSD2 already guarantees an excellent service level. PSPs, in a competitive market, should be free to add services depending on customers’ needs. • Increased regulation requires PSPs to adapt systems for compliance. That inevitably impacts on the ability to innovate in the instant payments space. New challenges arise for the payment services due to the real time expectations emanating from the digitalisation process; some of them certainly require a different regulatory framework (i.e. AML, CTF monitoring, fraud prevention and recovery tools). The measures required to protect the system, so that it keeps the necessary security level to be the support of Europe’s economic and financial sovereignty, cannot be achieved by market participants only, with the existing regulatory framework. Before proposing any measure on end-user payment solutions, authorities should carefully assess the approach to fragmentation (not to be confused with diversity) considering that this is uncharted territory for regulators. Intervention could have collateral effects on the payment instruments’ offer and competition. Before regulating final solutions, authorities should explore if the benefits of some standardisation of end-user payment solutions would offset its costs (decreased competition and innovation) or limit the market choices. The pricing of SCTInst associated services
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Meeting with Tommy De Temmerman (Cabinet of Commissioner Mairead Mcguinness)

2 Mar 2021 · Basel III and Covid Response

Response to Enhancing the convergence of insolvency laws

9 Dec 2020

Attach file with feedback
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Response to Consumer Credit Agreement – review of EU rules

1 Sept 2020

SPANISH BANKING ASSOCIATION’S COMMENTS TO THE EUROPEAN COMMISSION’S PUBLIC CONSULTATION ON AN INCEPTION IMPACT ASSESSMENT ON CONSUMER CREDIT DIRECTIVE.
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Response to Strengthening the consideration of sustainability risks and factors for financial products (Regulation (EU) 2017/565)

6 Jul 2020

The Spanish Banking Association welcomes the opportunity to respond to the draft amendments of the MiFID Delegated Regulation. Please find enclosed our full response.
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Response to Strengthening the consideration of sustainability risks and factors for financial products (Directive (EU) 2017/593)

6 Jul 2020

The Spanish Banking Association welcomes the opportunity to respond to the draft amendments of the MiFID Delegated Directive. Please find enclosed our full response.
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29 Nov 2018 · Introductory Meeting.

Meeting with Paulina Dejmek Hack (Cabinet of President Jean-Claude Juncker)

28 Nov 2018 · Fintech, Banking Union and Capital Markets Union

Response to Development of secondary markets for non-performing loans

8 Jun 2018

The Spanish Banking Association welcomes the opportunity to share our views on the draft Proposal for a Directive of the European Parliament and of the Council on credit servicers, credit purchasers and the recovery of collateral, issued by the European Commission. We support all the main messages included in the European Banking Federation response in which we have actively participated. However, we would like to stress some additional comments which we consider important.
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Response to Public consultation on minimum requirements in the transmission of information for the exercise of shareholders rights

9 May 2018

The Spanish Banking Association welcomes the opportunity to share our views on the draft Implementing Regulation laying down minimum requirements as regards shareholder identification, transmission of information and facilitation of the exercise of shareholders rights, issued by the European Commission.
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Meeting with Valdis Dombrovskis (Vice-President) and

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Meeting with Miguel Arias Cañete (Commissioner)

7 Feb 2017 · economic situation in Spain

Meeting with Margrethe Vestager (Commissioner)

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24 Mar 2015 · Banking Issues