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Eurofinas

The mission of Eurofinas is to represent and promote the interests of its members at European level as the natural voice of the specialised consumer credit providers in Europe.

Lobbying Activity

Response to Digital Fairness Act

24 Oct 2025

Please find attached the response of Eurofinas, the voice of specialised consumer credit providers at the EU level.
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Response to Digital package – digital omnibus

14 Oct 2025

Please find the feedback of Eurofinas, the voice of specialised consumer credit providers at the EU level, on the Digital Omnibus attached.
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Response to Consumer Agenda 2025-2030 and Action Plan on Consumers in the Single Market

31 Aug 2025

Please find the feedback of Eurofinas, the EU federation representing specialised consumer credit providers.
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Meeting with Arba Kokalari (Member of the European Parliament, Rapporteur) and Salesforce Inc.

15 Apr 2025 · AI in Financial Services

Meeting with Maravillas Abadía Jover (Member of the European Parliament)

5 Feb 2025 · Priorities in JURI Committee

Meeting with Jonás Fernández (Member of the European Parliament)

17 Apr 2024 · FIDA

Response to Consumer Credit Agreement – review of EU rules

2 Sept 2021

Eurofinas, the voice of European specialised consumer credit providers, welcomes the opportunity to respond to the European Commission’s consultation on its proposal for an updated European consumer credit framework. Consumer credit is a key component for the functioning of the European economy and an important contributor to consumption, as a key enabler for the sales of modern energy-efficient cars and other durable consumer goods. As a vital instrument in the recovery and restart of the European economy after COVID-19, it is essential that any changes to legislation must be carefully considered and clearly justified in order to avoid jeopardizing the re-start of the European economy. Proportionality The Commission’s proposal is seeking to address a number of issues through broad and sweeping measures. This will risk to endanger the relevant flexibility and proportionality facilitated under the existing framework, and, ultimately, risk the availability and provision of simple and consumer-focused products, e.g. all smaller loans below 200€, zero-interest rate loans or loans to be repaid within three months with no or only negligible charges. Without a greater focus on the enforcement of the existing rules and more specific policy responses to the raised issues, i.e. payday lending, the Commission’s proposal will risk to lead to unwarranted consumer detriment and financial exclusion through restrictions of offered products/loans due to the complete lack of proportionality. All in all, it is vital to ensure that the framework remains relevant and proportionate vis-à-vis the various products offered and in all the processes required under the framework, not least in relation to such well-established, simple and appreciated products mentioned above for which the full application of the framework is not justified nor proportionate. Moreover, it is necessary that any measures taken must carefully align with both national and European prudential regulatory frameworks to avoid adverse and quite often unintended consequences, as well as other relevant legislation covering decision-making processes, such as the GDPR.   Avoiding information overload Moreover, it is needed to address the issue of information overload, and fundamentally simplify the relevant requirements for the benefit of consumers by avoiding the duplication of information at the various stages, i.e. at the advertising, pre-contractual information and contractual stages. A fundamental part in this would be to focus on either the SECCI or the SECCO and by providing the relevant flexibility to allow for a focus on key details and most relevant aspects (APRC and the monthly installments, etc.). No save-all-solutions and responding to exceptional circumstances The framework has also proven to be robust and responsive to the situation and the specific challenges brought on by the COVID-19 crisis. It has enabled lenders and other concerned stakeholders to act to ensure the financial stability and health of its customers. The overall set of public and private measures that were implemented by the industry have enabled timely and appropriate support to consumers facing difficulties, the vast majority able to swiftly return their finances to a more normalised situation. Longer-term, however, in order to provide adequate support on a case-by-case basis, solutions must be sought at the local level allowing for tailor-made solutions that take into account the individual situation as well as the comprehensive, and often highly divergent, legal frameworks applicable. This is relevant with regards to e.g. the newly introduced provisions on non-discrimination which effectively amount to a general obligation to provide cross-border credit within the EU. They are unworkable as a result of the inability to appropriately assess the lender’s creditworthiness and risk profile due to the above-mentioned reasons.
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Meeting with Valdis Dombrovskis (Executive Vice-President) and

28 May 2020 · COVID-19 relief measures

Response to Review of the European Supervisory Authorities

23 Jan 2018

Eurofinas, the voice of consumer credit providers at European level takes note of the work of the European Commission to review the European System of Financial Supervision. We very much value and support the work to improve the definition of the ESAs’ mandate and institutional framework in order to increase their effectiveness. In our opinion, the ESAs sometimes go further than what is needed or foreseen at “level one” regulation, for example with regard to product oversight and governance arrangements. This is why we support the European Commission’s proposal for new tools to safeguard the powers of the ESAs to develop guidelines and recommendations. It is our view that the present funding model strikes a good balance between contributions from national supervisors and the EU budget. A contribution from the EU’s budget is warranted since ESAs’ supervision provides public goods such as financial stability and consumer protection. We consider that a complete halt to use EU funds for the ESAs’ budget would not be consistent with the importance of EU-wide supervision of the financial services sector and the pressure put on the industry over the past years. As acknowledged by the European Commission, the approach taken to fund supervisors differs widely across EU Member States. We have difficulties with the introduction of a harmonised funding system of the ESAs that is in fact disconnected from the funding system of supervisors at national level. We believe that it should be for Member States to decide how to fund their contributions to the ESAs. In any case, the principle of proportionality must be central to any decision taken on how contributions to the ESA budget are to be allocated. Against this backdrop, we highly support the European Commission’s efforts to ensure a proportionate approach. However, we take the view that a fair and transparent application of the proportionality principle requires a contextual analysis. A unique criterion related to the size of a balance sheet seems to go against the current European supervisory methodology which precisely aims at a risk-based approach. The limited and specialised activities of the relatively smaller institutions that Eurofinas represents does not require the same volume of supervisory resources than larger systemic institutions. Contributions should be based on the size but also the complexity of the institutions. It is vital to ensure that smaller institutions are not excessively burdened by changes to the current funding regime, especially since this would have a direct impact on their competitiveness in the market as well. In this respect, we strongly urge the European institutions consider low-risk criteria, including: • Size of the activity based on existing thresholds as defined by the ECB/SSM and or the EBA for non-Eurozone institutions • Size of the trading and derivatives books (for which we would advocate to define a relevant threshold at level 2) In addition to these technical criteria, we think there is space to develop a more qualitative assessment which can use the Supervisory Review and Evaluation Process (SREP) as a benchmark. SREP well- established indicators which are already used throughout the EU by supervisory authorities are valid criteria in this respect. These include for example: • Business model, profitability • Internal governance and control • Risk to capital • Risk to liquidity and funding • NPL ratio
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Meeting with Elina Melngaile (Cabinet of Vice-President Valdis Dombrovskis) and Finance Leasing Association

16 Jun 2017 · Action Plan on Consumer Financial Services

Meeting with Kevin O'Connell (Cabinet of Commissioner Věra Jourová)

19 Oct 2015 · Data Protection