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Association des Banques et Banquiers, Luxembourg

ABBL

The Luxembourg Bankers' Association represents banks and financial sector professionals in Luxembourg on regulatory, employment, and training matters.

Lobbying Activity

Luxembourg Bankers Urge Simplification of EU Green Taxonomy Rules

5 Dec 2025
Topic — This consultation reviews EU taxonomy rules to update and simplify technical screening criteria.
Message — The association wants to remove or simplify environmental and social checks for investments. They also demand more flexibility when required data is not available.123
Why — These changes would streamline compliance processes and lower regulatory costs for banks.45
Impact — Environmental and social groups lose protections that ensure investments do no harm.67
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Meeting with Marc Angel (Member of the European Parliament) and FEDIL - The Voice of Luxembourg's Industry and

3 Dec 2025 · Competitiveness

Meeting with Gilles Boyer (Member of the European Parliament) and Association Luxembourgeoise des Fonds d'Investissement and Association des compagnies d’assurances et de réassurances du Grand-Duché de Luxembourg

14 Nov 2025 · SIU, Pension package, Savings and Investment Accounts, Market integration package

Meeting with Cristina Dias (Cabinet of Commissioner Maria Luís Albuquerque), Philippe Thill (Cabinet of Commissioner Maria Luís Albuquerque) and

23 Oct 2025 · Discussion on simplification and the Savings and Investments Union

Meeting with Michael Hager (Cabinet of Commissioner Valdis Dombrovskis)

7 Oct 2025 · Competitiveness, simplification and SIU

Meeting with Alexandra Jour-Schroeder (Deputy Director-General Financial Stability, Financial Services and Capital Markets Union) and Association Luxembourgeoise des Fonds d'Investissement and Association des compagnies d’assurances et de réassurances du Grand-Duché de Luxembourg

19 Sept 2025 · Financial sector’s priorities

Luxembourg Bankers Advocate for Streamlined EU Securitisation Rules

14 Jul 2025
Topic — The consultation examines the EU securitisation framework including liquidity and prudential requirements.
Message — The organization requests streamlined due diligence and a thirty-five percent reduction in reporting requirements. They emphasize that clear guidance is essential to avoid inconsistent interpretation across the market.123
Why — This would decrease their operational costs while providing capital relief for senior tranches.45
Impact — EU markets lose competitiveness if strict listing definitions drive issuers to foreign venues.6
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Meeting with Maria Luís Albuquerque (Commissioner) and

18 Jun 2025 · Working lunch with financial associations on the Savings and Investments Union

ABBL urges EU to simplify sustainable finance disclosure rules

30 May 2025
Topic — The EU is reviewing rules to simplify sustainable finance disclosures and prevent greenwashing.
Message — ABBL calls for simplified disclosure templates and better alignment between different financial regulations. They recommend removing redundant reporting requirements and limiting pre-contractual documents to three pages.123
Why — Streamlined reporting would lower administrative costs and reduce technical complexity for bank staff.45
Impact — Transparency advocates lose access to specific public disclosures if website reporting requirements are removed.67
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Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union) and Association Luxembourgeoise des Fonds d'Investissement and Association des compagnies d’assurances et de réassurances du Grand-Duché de Luxembourg

22 May 2025 · Exchange of views on topics related to Savings and Investment Union, Internal Market and simplification.

Meeting with Martine Kemp (Member of the European Parliament)

13 May 2025 · Lunch debate: Encouraging retail investment in the EU - A key to today’s main challenges

Meeting with Martine Kemp (Member of the European Parliament) and FEDIL - The Voice of Luxembourg's Industry

20 Mar 2025 · general meeting

Meeting with Pawel Wisniewski (Cabinet of Commissioner Christophe Hansen) and Association Luxembourgeoise des Fonds d'Investissement and Association des compagnies d’assurances et de réassurances du Grand-Duché de Luxembourg

25 Feb 2025 · Role of the financial sector in financing agriculture and rural areas

Meeting with Maive Rute (Deputy Director-General Internal Market, Industry, Entrepreneurship and SMEs) and FEDIL - The Voice of Luxembourg's Industry and

6 Feb 2025 · Stakeholders’ roundtable in Luxembourg – Single Market Strategy Consultation

Meeting with Martine Kemp (Member of the European Parliament)

5 Feb 2025 · Follow-Up on the Capital Markets Union Discussion

Meeting with Marc Angel (Member of the European Parliament) and FEDIL - The Voice of Luxembourg's Industry and

18 Dec 2024 · ECON and IMCO-related issues

Response to Evaluation of Administrative Cooperation in Direct Taxation

30 Jul 2024

The Luxembourg Bankers Association (ABBL) is the largest association of the financial sector in Luxembourg with more than 270 members, representing the majority of financial institutions as well as market infrastructures, e-money and payment institutions and other regulated financial services providers operating in Luxembourg. Its primary mission is to promote the sustainable development of regulated, innovative and responsible banking services in Luxembourg. The ABBL is fully committed to tax transparency and is providing its members assistance in a compliant and consistent implementation of the underlying exchange of information standards in Luxembourg. We welcome the opportunity to contribute to the public consultation launched by the European Commission on the Directive on Administrative Cooperation (hereafter DAC). Comments provided in attachment reflect the views of our members and thus focus on the role of banks as financial intermediaries in the context of DAC 2 and DAC 6.
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Meeting with Marc Angel (Member of the European Parliament)

17 Jul 2024 · ECON-related issues

Luxembourg banking group calls for clearer financial data rules

31 Oct 2023
Topic — The EU initiative establishing a framework for sharing financial customer data.
Message — The association requests clearer data definitions and exemptions for trade secrets. They advocate for longer implementation timelines and standardized permission dashboards.12
Why — Excluding trade secrets and extending timelines would reduce compliance risks and costs.34
Impact — Fintech firms and data users would receive less data and face delays.56
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Meeting with Marc Angel (Member of the European Parliament)

26 Oct 2023 · CMDI, Retail Investment Strategy

Luxembourg bankers demand optional status for EU tax relief

18 Sept 2023
Topic — This consultation proposes a common, standardized EU-wide system for withholding tax relief.
Message — The ABBL calls for making the new tax relief procedures optional for financial intermediaries. They request more proportionality in reporting requirements and a delayed implementation until July 2028.123
Why — This would prevent compliance costs and legal liabilities from outweighing the policy's benefits.4
Impact — Smaller financial institutions may face barriers to entry for providing securities services.5
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Response to Banking Union: Review of the bank crisis management and deposit insurance framework (DGSD review)

28 Aug 2023

The ABBL welcomes the underlying objective of the Commissions proposal for a Crisis Management and Deposit Insurance framework (hereafter CMDI), which aims notably at: Broadening the application of resolution tools in crisis management at European and national level including for smaller and medium-sized banks; Extending the use of privately funded safety nets (i.e. Deposit Guarantee Schemes Funds and Resolution Funds) to reinforce the crisis management toolbox, as a complement to banks internal loss absorption capacity. Notwithstanding this, the ABBL would like to draw the attention on the consequences of this proposal, which constitutes a paradigm shift compared to the existing framework. Indeed, financing is the pivotal issue of the CMDI proposal, because extending the use of resolution to a broader population of banks will put pressure on national Deposit Guarantee Funds and on the European Single Resolution Fund. Consequently, there is a real risk that banks financial contributions will significantly increase over time as these Funds will be depleted, putting at risk the competitive position of the banking sector and financial stability. In this respect, transparency on the use of the Funds is crucial for contributors to appreciate their level of expected or future contributions. With regard more specifically to deposit insurance, some amendments proposed by the Commission deserve further clarification, in particular broadening eligible deposits to public authorities and to clients funds deposits. Against this background, the ABBL would welcome several adjustments compatible with the Commissions objectives, along the following priorities: Adding safeguards for the use of Deposit Guarantee Schemes (hereafter DGSs) funds in resolution; Ensuring a level playing field among banks by requiring a minimum level of MREL for banks subject to transfer strategies; Specifying early intervention rights and triggers by the Authorities to prevent late intervention and excessive use of DGSs resources; Removing the proposed amendments on the use of the Irrevocable Payment Commitments (IPCs), which would cancel the P&L benefits of IPCs with retroactive effect, by forcing banks to recycle the existing stock through P&L; Framing the use of preventive measures financed by DGSs; Clarifying the definition of public authorities for the purpose of deposit insurance; As for clients funds deposits eligible to the deposit insurance, specifying the practical conditions for identifying clients funds deposits and considering some unintended consequences for deposit-taking banks.
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Response to Banking Union: Review of the bank crisis management and deposit insurance framework (DGSD review)

28 Aug 2023

The ABBL welcomes the underlying objective of the Commissions proposal for a Crisis Management and Deposit Insurance framework (hereafter CMDI), which aims notably at: Broadening the application of resolution tools in crisis management at European and national level including for smaller and medium-sized banks; Extending the use of privately funded safety nets (i.e. Deposit Guarantee Schemes Funds and Resolution Funds) to reinforce the crisis management toolbox, as a complement to banks internal loss absorption capacity. Notwithstanding this, the ABBL would like to draw the attention on the consequences of this proposal, which constitutes a paradigm shift compared to the existing framework. Indeed, financing is the pivotal issue of the CMDI proposal, because extending the use of resolution to a broader population of banks will put pressure on national Deposit Guarantee Funds and on the European Single Resolution Fund. Consequently, there is a real risk that banks financial contributions will significantly increase over time as these Funds will be depleted, putting at risk the competitive position of the banking sector and financial stability. In this respect, transparency on the use of the Funds is crucial for contributors to appreciate their level of expected or future contributions. With regard more specifically to deposit insurance, some amendments proposed by the Commission deserve further clarification, in particular broadening eligible deposits to public authorities and to clients funds deposits. Against this background, the ABBL would welcome several adjustments compatible with the Commissions objectives, along the following priorities: Adding safeguards for the use of Deposit Guarantee Schemes (hereafter DGSs) funds in resolution; Ensuring a level playing field among banks by requiring a minimum level of MREL for banks subject to transfer strategies; Specifying early intervention rights and triggers by the Authorities to prevent late intervention and excessive use of DGSs resources; Removing the proposed amendments on the use of the Irrevocable Payment Commitments (IPCs), which would cancel the P&L benefits of IPCs with retroactive effect, by forcing banks to recycle the existing stock through P&L; Framing the use of preventive measures financed by DGSs; Clarifying the definition of public authorities for the purpose of deposit insurance; As for clients funds deposits eligible to the deposit insurance, specifying the practical conditions for identifying clients funds deposits and considering some unintended consequences for deposit-taking banks.
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Luxembourg Bankers Warn Against Proposed EU Investment Price Intervention

25 Aug 2023
Topic — The consultation concerns legislative proposals to increase retail investor participation in capital markets.
Message — ABBL strongly opposes product benchmarking based only on costs and performance. They seek to maintain current inducement rules and reject new suitability tests.123
Why — This would protect existing revenue streams from commissions and prevent aggressive price regulation.4
Impact — Independent advisors lose the proposed regulatory exemptions that would give them a market advantage.5
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Meeting with Marc Angel (Member of the European Parliament) and Association Luxembourgeoise des Fonds d'Investissement

8 Jun 2023 · ECON-related issues

Meeting with Marc Angel (Member of the European Parliament) and Association Luxembourgeoise des Fonds d'Investissement

16 Jun 2022 · AIFMD, CRR, CRD

Luxembourg banks urge alignment of retail investor protection rules

31 May 2022
Topic — This consultation seeks to improve retail investor confidence and participation in capital markets.
Message — ABBL requests a holistic review to align contradictory rules and reduce complexity. They propose making digital communication the default and regulating social media platforms.123
Why — Aligning regulations would reduce the legal uncertainties and operational risks currently facing banks.45
Impact — Unregulated digital platforms would lose the advantage of operating without strict investor protections.6
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Meeting with Gilles Boyer (Member of the European Parliament, Rapporteur)

18 Feb 2022 · CRR (staff)

Meeting with Ramona Strugariu (Member of the European Parliament, Shadow rapporteur) and Association Luxembourgeoise des Fonds d'Investissement

14 Jan 2022 · Anti-money laundering package

Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union) and Association Luxembourgeoise des Fonds d'Investissement

11 Jan 2022 · Banking Package, Mifid

Meeting with Mairead McGuinness (Commissioner) and

13 Dec 2021 · Overview of recent and upcoming regulatory initiatives in financial services

Meeting with Mairead McGuinness (Commissioner) and

22 Apr 2021 · Basel III, capital markets regulation, AML. AIFMD

Meeting with Nicolas Schmit (Commissioner) and

12 Mar 2021 · Meeting on the funds and banking sector in Luxembourg, teleworking and the Right to Disconnect (R2D).

Response to Amendment to the LCR Delegated Regulation

24 Nov 2020

The ABBL welcomes the opportunity to comment the amendments proposed to the Delegated Regulation (EU) 2015/61 on liquidity coverage requirement for credit institutions. Our comment refers to the amendments to Article 10(1), point (f) (i), Article 11(1), point (c) (i) and Article 12(1), point (e) (i) of the exisiting Delegated Regulation. Currently, in order to qualify as Level 1, Level 2A or Level 2B assets, these Articles require that exposures in the form of covered bonds have - amongst others - to comply with the following requirements: [...] they are bonds as referred to in Article 52(4) of Directive 2009/65/EC or meet the requirements to be eligible for the treatment set out in Article 129(4) or (5) of Regulation (EU) No 575/2013 [...]. However, the proposed amendments now refer to Article 129 CRR only by deleting Article 52(4), rather than replacing Article 52(4) UCITS and Article 129 CRR with a reference to the the Covered Bonds Directive (allowing all type of covered bonds to qualify as liquid assets as long as they comply with the Covered Bonds Directive). We believe that all covered bonds falling under the Covered Bonds Directive should qualify as Level 1, Level 2A or Level 2B assets and not only CRR compliant covered bonds. If the Commission proposal was adopted, this would lead to a situation in which asset-backed securities and even shares would qualify as Level 2B assets, while European covered bonds complying with the Covered Bonds Directive would not qualify at all as eligible (high quality) asset for LCR purposes. Such an approach would create an unlevelled playing field to the expense of covered bonds. Also, it would undermine the intention and the initial motivation of creating a European wide, harmonised covered bond definition for regulatory purposes.
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Meeting with Antoine Kasel (Cabinet of Commissioner Nicolas Schmit)

2 Sept 2020 · Tour d’horizon de l’actualité européenne et situation de l’emploi dans le secteur financier luxembourgeois

Response to Action Plan on the Capital Markets Union

22 Jul 2020

The development of deeper, autonomous and more integrated capital markets is critical to transform the EU into an attractive and competitive economy and marketplace. The key issue at hand is the outset of the financing of the European economy, which is traditionally built on bank credit. While the situation has changed since the 2008 financial crisis, the EU27 market-based financing still lags behind. With bank credit being significantly more constrained since 2008 through the various post-crisis reforms, banks are required to maintain large reserves of liquid assets with low returns. Furthermore, the current regulation tends to shorten the timelines and the financing horizon even though long-term financing becomes a real issue for the EU economy. Finally, the ongoing regulatory developments are affecting access to financing with increased cost and complexity. Hence bolstering market financing is the most important concern to address under the CMU to answer the changing financing needs of the real economy, by allowing clients to participate directly to the growth in EU markets. A successful CMU will further strengthen the stability of financial markets through risk sharing across the EU markets, as well as the global competitiveness and sovereignty. Indeed, financial integration provides risk sharing mechanisms that can reduce the impact of country-specific shocks and contributes to macroeconomic stability. Internationally diversified portfolios – cross-regional and cross-border asset holdings, including firm ownership claims – are more resilient to global and local shocks and can mitigate the impact of such adverse scenarios. Increased private financial risk sharing can significantly improve the macroeconomic stabilisation of the euro area and thereby the functioning of the EMU. It is further painfully obvious in the COVID-19 crisis that the lack of EU capital markets integration is hampering the development of adequate financing means to kickstart the EU economy in order to deter the development of a major economic crisis in the follow-up of the sanitary crisis. Fully developed EU27 markets would indeed bring about the required tools to finance the economy and the corporates hit by the lockdown of the economy. In light of these issues, the ABBL has identified three main priorities to build integrated EU capital markets: (1) Strengthen securitisation as a tool and a market – The Simple and Transparent Securitisation Regulation needs to be reviewed for the potential of this product to develop its fullest potential. The future regime should require less prudential requirements by giving banks the tools to lighten lending-driven balance sheets and thereby provide investors with viable and interesting investment alternatives; (2) Channel savings and investments into sustainable activities – Sustainable finance activities are the future of the financial sector and therefore it is crucial to create and sustain an adequate regulatory framework ensuring qualitative services and products. The creation of a liquid market for green bonds, i.e. greenfield (from scratch) and brownfield (greening of existing infrastructure), is an important milestone for a larger public interest in sustainable investment possibilities. Coupled with the development of green securitisation, this will be further encouraged through a meaningful disclosure requirements on ESG compliance and an appropriate ESG integration in asset classes and investment strategies. Financial and prudential regulation as (dis-)incentive should be used with an appropriately cautious approach; (3) Improve withholding tax relief and refund procedures – By simplifying WHT procedures, it will be possible to build a saver-friendly and investor-friendly tax system that guarantees the tax reliefs for savers and investors under double tax treaties. This new efficient WHT relief and refund system will eventually serve as boost for cross-border investments and securities services.
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Meeting with Nicolas Schmit (Commissioner), Thierry Breton (Commissioner) and

6 Jul 2020 · Entrevue sur les investissements dans les compétences et la transition numérique pour accélérer la reprise, les stratégies numériques et industrielles, les PME.

Meeting with Valdis Dombrovskis (Vice-President) and

15 Nov 2018 · ESAs review package, Brexit, Sustainable Finance

Meeting with Michel Barnier (Head of Task Force Task Force for Relations with the United Kingdom)

17 Jul 2018 · Meeting with the Task Force for the Preparation and Conduct of the Negotiations with the United Kingdom under Article 50 TEU

Response to Review of the European Supervisory Authorities

22 Jan 2018

The Luxembourg Bankers’ Association (the ABBL) is keen to comment the Commission proposal amending the EBA founding Regulation released on 20 September 2017. Overall we have strong reservations on the proposal since there is no proven deficiency in the European supervisory framework that would justify the far-reaching approach adopted by the Commission. The Commission proposal should better reflect the different degrees of supervisory convergence and of integration reached by the sectors in the remit of the ESAs. Notably, the successful deployment of the SSM in the banking sector makes redundant the conferral of additional direct or indirect supervisory responsibilities to the EBA. Rather than changing radically the set-up of the supervisory framework for all ESAs, the Commission should create the right incentives to foster convergence in the sectorial frameworks where progress is still needed. The proposed governance dramatically jeopardizes the powers of the Board of Supervisors. Transferring key decisional powers (e.g. breaches of Union law, settlement of disagreements between National Competent Authorities, outsourcing / delegation to third countries) from the Board of Supervisors to the Executive Board questions the principle of separation of powers between the executive body and the supervisory body of the EBA. We believe that the actual Board of Supervisors is the adequate decision-making body, since the presence of national authorities ensures that both the EU view and national specificities are taken into consideration Supervisory costs will increase significantly. Worryingly, the proposal will also lead to a massive increase of supervisory costs to be born primarily by the banking industry. The Commission indeed proposes to replace the share of the funding provided by National Competent Authorities by contributions levied straight from the financial sector for at least 60% of the total budget: this mechanism introduces a further layer of cost for banks, which will have to pay three times for their supervision, i.e. to their National Competent Authority, to the ECB and to the EBA. Increased costs will exacerbate the concentration of the banking sector. lt is worth keeping in mind that the excessive increase of the current supervisory costs will proportionally penalize more small and medium-sized institutions, the capacity of which to absorb the regulatory burden is more limited than that of bigger players. We see there a real risk that small and medium-sized institutions be pushed out of the market, thus fostering further concentration in the banking sector. lt is widely accepted that, the diversity of the banking sector in terms of banks' business models and size contributes to financial stability, and it should not be put at risk by the uncontrolled inflation of supervisory costs. The new powers of EBA and ESMA on outsourcing / delegation of material activities to third countries’ entities constitute a disproportionate requirement creating uncertainty and additional costs for EU and non-EU financial cross-border groups. A second layer of verification by the EBA and ESMA would create undue costs, regulatory complexity and legal uncertainty that would harm the competitiveness of the EU banking industry. This is all the more problematic that there is no objective reason to assume that National Competent Authorities’ decisions to authorize delegation to third countries’ entities do not comply with EU rules, Finally, while we welcome some measures like the enhanced role of EBA in the equivalence decisions, we believe that the complexity and the costs introduced by the proposal broadly outweigh the expected benefits related to the financial integration of the banking sector.
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Meeting with Olivier Guersent (Director-General Financial Stability, Financial Services and Capital Markets Union)

14 Sept 2017 · ESA review, the RRM and EDIS

Response to Access of centralised bank account registries

23 Aug 2017

The ABBL would like to express its views with regard to the aforementioned topic and therefore encloses an attachment pertaining thereto.
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Meeting with Michel Barnier (Head of Task Force Task Force for Relations with the United Kingdom) and Association Luxembourgeoise des Fonds d'Investissement and Union des Entreprises Luxembourgeoises

4 Apr 2017 · Meeting with the Task Force for the Preparation and Conduct of the Negotiations with the United Kingdom under Article 50 TEU

Meeting with Valdis Dombrovskis (Vice-President) and

1 Mar 2017 · Banking; Investment fund distribution; EDIS

Meeting with Jonathan Hill (Commissioner)

2 Dec 2015 · Undertakings for Collective Investment in Transferable Securities Directive

Meeting with Maria Elena Scoppio (Cabinet of Commissioner Pierre Moscovici)

13 Oct 2015 · State of play on taxation files: FTT + CCCTB

Meeting with Jan Ceyssens (Cabinet of Vice-President Valdis Dombrovskis)

13 Oct 2015 · Financial regulation

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

13 Oct 2015 · Capital Markets Union