Bundesverband der Wertpapierfirmen e.V.
bwf
The Federal Association of Investment Firms (bwf) was founded in September 2003 on the initiative of the previous Federal Associations of Securities Brokers / Financial Intermediaries on the one hand and of Securities Trading Firms on the other.
ID: 258694016925-01
Lobbying Activity
Meeting with Tatyana Panova (Head of Unit Financial Stability, Financial Services and Capital Markets Union)
2 Sept 2025 · SIU – market integration
Response to Recommendation on savings and investment accounts
8 Jul 2025
bwf Feedback on the Commission's Call for Evidence Recommendation on Savings and Investment Accounts The Bundesverband der Wertpapierfirmen (bwf), representing investment firms and credit institutions focused on MiFID investment services in Germany, welcomes the European Commissions initiative to promote retail participation in capital markets via savings and investment accounts (SIAs). We fully support the overarching goals: enhancing long-term wealth creation for EU citizens and improving capital allocation to European businesses, especially SMEs. Properly designed SIAs can unlock retail capital and foster a long-term investment culture. The success of this initiative depends on national flexibility, appropriate incentives, and effective competition. Overly prescriptive EU definitions risk stifling innovation and ignoring national specificities. Therefore, a recommendation-based approach, rooted in subsidiarity, incentives, and open competition, seems to be most promising. Key considerations: Product Eligibility and Access: We support broad eligibility (equities, bonds, ETFs, UCITS, certain structured products) given that certain investor protection standards are met. National authorities should retain some discretion based on local market conditions. Digital and Simple Access: We support streamlined digital onboarding, ideally through existing apps and banking channels. Standardised interfaces and harmonised disclosures aligned with MiFID II/MiFIR could enhance transparency and comparability. Portability and Cost-Efficiency: Easy portfolio transfers or provider switching at minimal costs can increase competition and improve (potential) investors acceptance. However, technical complexities, including tax treatment, must be realistically addressed. Also, cross-border portability could further encourage competition and lower fees. Cross-Border Provision and Competition: bwf supports cross-border competition and the provision of investor-initiated cross-border services. At the same time, well established local distribution- and execution models, must not be impeded. It must be noted that past initiatives by EU legislators to facilitate retail access to simple savings and investment products had only limited success. Tax Incentives and Simplification: Tax incentives are crucial. We support simplified taxation models (e.g., flat tax, automatic deferral, pre-filled declarations). The Danish and Swedish models show that predictable flat tax structures can boost participation. Since tax remains a national matter, EU guidance should emphasize neutrality, simplicity, and transparency rather than uniform design. Systemic Barriers in Post-Trading Infrastructure: Europes fragmented post-trading infrastructure remains a major obstacle to mobilizing savings and attracting investment. The EU operates with 27 effectively still fragmented, making cross-border trading and even more listings complex and unnecessarily expensive. Greater interoperability, reduced transaction costs, and enhanced post-trade competition should be priorities. Regulatory Approach and Monitoring: This initiative must be aligned with MiFID II, PRIIPs, and national regimes to avoid duplication or added complexity. SIAs should simplify the landscape. While consistent indicators are important for monitoring retail participation and capital formation, national flexibility in reporting design should be given due attention. Conclusion: bwf strongly supports the Commissions initiative to boost retail investor participation. Achieving success requires a balanced approach between EU-level coordination and national discretion. We are ready to contribute further to legislative design and implementation discussions.
Read full responseResponse to Savings and Investments Union
3 Mar 2025
Response to the European Commissions Call for Evidence on the Savings and Investments Union (SIU): On behalf of bwf, representing German investment firms, we welcome the opportunity to contribute to the development of the SIU. Europes capital markets remain fragmented, limiting their ability to mobilize savings and attract investment. While the Commissions push for an SIU highlights the need for reform, a one-size-fits-all harmonization approach risks overlooking core issues. Rather than excessive regulatory alignment, Europe must focus on incentivizing investment through targeted tax policies and addressing systemic barriers to cross-border listings and investments. The Danish model demonstrates how tax incentives can stimulate retail investment. Investment savings accounts (ISAs) with simplified taxation have significantly increased market participation, as seen in Denmark, Sweden, and Finland. A flexible EU-wide ISA framework, based on best practices rather than rigid standardization, could allow member states to tailor incentives to their tax regimes while encouraging retail investor participation. However, this framework should remain voluntary to accommodate national economic contexts while fostering a broader investment culture. For instance, Swedens Investment Savings Account (ISK) eliminates capital gains tax on sales within the account and applies a predictable flat tax, boosting fund participation. The Commission should encourage similar initiatives without imposing rigid, top-down regulation. Beyond tax incentives, Europes fragmented post-trading infrastructure remains a major obstacle. The EU operates with 27 inefficient, costly, and siloed markets, making cross-border listings complex and expensive. Unlike the U.S., where a unified market allows companies to raise capital efficiently, the EUs multiple Central Securities Depositories (CSDs) create unnecessary layers of cost and complexity. Cross-listings between EU states should be straightforward but are hindered by settlement system incompatibilities and excessive regulatory burdens. Instead of further harmonization, the EU should prioritize interoperability between CSDs, reduce transaction costs, and foster competition in post-trading services. Market monopolies continue to impose excessive fees, limiting competition and access. A fairer, more transparent framework is needed to enhance market efficiency and support SMEs and retail investors. While regulatory harmonization can reduce inefficiencies, excessive top-down rules risk increasing costs rather than solving market fragmentation. A competitive European capital market requires reducing bureaucracy and leveraging national best practices. Tax incentives at the member-state level, combined with an open and efficient post-trading environment, will strengthen the Capital Markets Union (CMU) more effectively than additional layers of EU-wide regulation. Europe must choose between costly regulatory centralization or pragmatic, market-driven solutions. Tax incentives based on successful national models can drive retail investor participation, while eliminating settlement system fragmentation will unlock cross-border investment potential by reducing costs and operational complexities. Rather than pursuing a centrally controlled capital market, policymakers should focus on interoperability, competition, and efficiency. Addressing these core issues will foster a dynamic and resilient financial system that supports economic growth and competitiveness.
Read full response10 Sept 2020
The Bundesverband der Wertpapierfirmen e.V.(bwf) is a trade association representing the common professional interests of securities trading firms, market specialists (market makers) at the securities exchanges throughout Germany and other investment firms. In this capacity, we expressly welcome the possibility to comment on the draft COMMISSION DELEGATED DIRECTIVE (EU) .../… amending delegated directive (EU) 2017/593 as regards the regime for research on small and mid-cap issuers and on fixed-income instruments to help the recovery from the COVID-19 pandemic. Please refere to the enclosed PDF-document for our comments.
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