OpenLobby.EU

European Banking Federation

EBF

The European Banking Federation represents national banking associations from 45 countries, advocating for a stable, secure, and inclusive European financial ecosystem.

Lobbying Activity

Meeting with Luděk Niedermayer (Member of the European Parliament)

12 Nov 2025 · Banking competitiveness

Banking Federation Calls for Financial Incentives to Scale Circularity

6 Nov 2025
Feedback on — EU regulation to enhance circular economy, secondary materials supply, and recycling demand.
Their ask — The organization requests economic incentives and public-private financing mechanisms to make circular products competitive with virgin materials. They propose creating a Circular Economy Bank offering off-take guarantees and integrating circular principles into EU financing instruments. They emphasize that circular products are currently more expensive than alternatives, requiring policy intervention.123
How it helps them — This would reduce financing risks for banks and create profitable opportunities for circular lending.45
Who loses — Virgin material producers lose market share as recycled content requirements reduce virgin extraction demand.6
Response to: Circular Economy Act

Meeting with Almoro Rubin De Cervin (Head of Unit Financial Stability, Financial Services and Capital Markets Union) and

14 Oct 2025 · Prudential treatment of banks’ exposures to crypto-assets

European Banking Federation seeks exemption from cyber rules and AI clarity

13 Oct 2025
Feedback on — EU initiative to simplify digital regulations including data sharing, cybersecurity and AI rules.
Their ask — Banks want exemption from the Cyber Resilience Act, arguing their sector-specific DORA regulation already covers cybersecurity comprehensively. They seek clarity on AI definitions to exclude basic statistical models like logistic regression. They request withdrawing or reassessing the Financial Data Access regulation, calling for voluntary market-driven data sharing instead.123
How it helps them — This would reduce duplicative compliance obligations and free resources from regulatory compliance tasks.456
Who loses — Consumers may face weaker protections if cross-sectoral data sharing remains voluntary without mandatory safeguards.7
Response to: Digital Omnibus revising several legislative acts in view of regulatory simplification

Meeting with Eric Ducoulombier (Acting Director Financial Stability, Financial Services and Capital Markets Union)

10 Oct 2025 · Commission’s priorities and potential initiatives in the area of retail financial services.

Meeting with Eric Ducoulombier (Acting Director Financial Stability, Financial Services and Capital Markets Union) and

9 Oct 2025 · Implementation of two obligations for payment service providers under the Instant Payments Regulation

Meeting with Ton Diepeveen (Member of the European Parliament, Shadow rapporteur)

8 Oct 2025 · Overleg

Meeting with Ralf Seekatz (Member of the European Parliament, Rapporteur)

8 Oct 2025 · Verbriefung

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

7 Oct 2025 · Banking and digital matters

Meeting with Katarina Koszeghy (Cabinet of Commissioner Wopke Hoekstra) and Fédération bancaire française

4 Sept 2025 · FASTER Directive

Meeting with Henna Virkkunen (Executive Vice-President) and

14 Jul 2025 · Digital policy and simplification

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

10 Jul 2025 · ESG risk management by banks

Meeting with Katarina Koszeghy (Cabinet of Commissioner Wopke Hoekstra)

30 Jun 2025 · Taxation of EU’s financial sector

Meeting with Almoro Rubin De Cervin (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

26 Jun 2025 · Banking policy

Meeting with Fernando Navarrete Rojas (Member of the European Parliament, Rapporteur)

23 Jun 2025 · Euro Digital

Banking Federation Seeks Clarification on Business Wallet Framework

12 Jun 2025
Feedback on — European wallets for business to streamline administrative tasks and cross-border operations.
Their ask — The organization requests clarification on how the Business Wallet relates to existing identity wallets and sectoral legislation. They emphasize the need to focus on digital credentials with a robust trust framework, prioritize public sector participation, and ensure flexibility for innovation. They want harmonized identification requirements to reduce fragmented national reporting obligations.1234
How it helps them — This would reduce compliance costs and eliminate fragmented national reporting requirements across borders.567
Who loses — National authorities lose control over setting their own identification and reporting standards.8
Response to: European wallets for business

European Banking Federation seeks simpler SFDR disclosures for retail investors

28 May 2025
Feedback on — EU review of sustainability disclosure rules for financial services sector.
Their ask — The federation wants to significantly simplify disclosure requirements, reduce the number of principal adverse impact indicators, and delete the annual PAI statement at entity level. They propose building new product categories on existing Article 8 and 9 frameworks rather than creating an entirely new system. They argue current disclosures are too complex and technical, leading to information overload that discourages retail investors from sustainable investing.1234
How it helps them — This would reduce their compliance costs and preserve existing investments in internal systems.567
Who loses — Investors lose detailed sustainability information needed to assess environmental and social impacts.8
Response to: Proposal for a Regulation of the European Parliament and Council amending Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector

Meeting with Almoro Rubin De Cervin (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

23 May 2025 · Banking issues

Meeting with Enikő Győri (Member of the European Parliament)

19 May 2025 · capital requirements

European Banking Federation Seeks Implementation Delay for Digital Identity Rules

13 May 2025
Feedback on — EU regulation on verification standards for qualified digital certificates and identity wallets.
Their ask — The banking associations request additional implementation time to make necessary technical adjustments. They argue the updated security standards and specific requirements for automated operations and document validation will require significant system updates.12
How it helps them — This would reduce their compliance costs and allow more time to adapt technical infrastructure.3
Response to: COMMISSION IMPLEMENTING REGULATION (EU) …/... laying down rules for the application of Regulation (EU) No 910/2014 of the European Parliament and of the Council as regards reference standards for the verification of the identity and attributes of person to whom the qualified certificate or the qualified electronic attestation of attributes is to be issued

European Banking Federation Seeks Clarity on Remote Identity Verification

13 May 2025
Feedback on — EU regulation on remote qualified electronic signature and seal creation devices.
Their ask — The banking sector requests clarification on how remote identity verification providers currently operating can continue under the new framework. They seek a robust and harmonised certification framework for European Digital Identity Wallets.12
How it helps them — This would allow banks' existing identity verification systems to remain operational.3
Response to: COMMISSION IMPLEMENTING REGULATION (EU) …/... laying down rules for the application of Regulation (EU) No 910/2014 of the European Parliament and of the Council as regards the management of remote qualified electronic signature creation devices and of remote qualified electronic seal creation devices as qualified trust services

European Banking Federation Seeks Clarity on Digital Identity Standards

13 May 2025
Feedback on — EU regulation on reference standards for qualified electronic signatures and seals.
Their ask — The banking sector requests clarification on how Remote Identity Verification Providers can continue operations under the new framework. They also recommend disallowing obsolete cryptographic algorithms like DSA without ECC for EU wallet use.12
How it helps them — This would preserve existing business models for identity verification services without EUDI Wallets.3
Who loses — The push for universal EUDI Wallet adoption could be weakened by carve-outs.
Response to: COMMISSION IMPLEMENTING REGULATION (EU) …/... laying down rules for the application of Regulation (EU) No 910/2014 of the European Parliament and of the Council as regards reference standards for qualified certificates for electronic signatures and qualified certificates for electronic seals

European Banking Federation Seeks Stronger Cryptography Standards for Digital Identity

13 May 2025
Feedback on — EU rules on validating electronic signatures and seals for digital identity wallets.
Their ask — The banking sector wants obsolete cryptographic algorithms banned from EU digital identity wallets and post-quantum cryptography integrated into technical standards. They argue current standards reference discontinued algorithms that don't meet wallet security requirements.12
How it helps them — This would protect banks from security vulnerabilities in outdated encryption systems.34
Response to: COMMISSION IMPLEMENTING REGULATION (EU) …/... laying down rules for the application of Regulation (EU) No 910/2014 of the European Parliament and of the Council as regards the validation of qualified electronic signatures and of qualified electronic seals and the validation of advanced electronic signatures based on qualified certificates and of advanced electronic seals based on qualified certificates

European Banking Federation Seeks Clarity on Remote Identity Verification Rules

13 May 2025
Feedback on — New EU regulation on qualified validation services for electronic signatures and seals.
Their ask — The organization requests clarification on how remote identity verification providers currently operating for qualified electronic signatures can continue under the new framework. They want the issue carefully considered to create a robust certification framework for digital identity wallets.12
How it helps them — This would allow banks to maintain existing identity verification services without disruptive changes.3
Response to: COMMISSION IMPLEMENTING REGULATION (EU) …/... laying down rules for the application of Regulation (EU) No 910/2014 of the European Parliament and of the Council as regards qualified validation services for qualified electronic signatures and qualified validation services for qualified electronic seals

European Banking Federation Seeks QTSP Exemption from Outsourcing Rules

13 May 2025
Feedback on — EU regulation on notification procedures for qualified trust services under eIDAS 2.0.
Their ask — The banking sector requests that Qualified Trust Service Providers not be classified as traditional outsourcers under ICT outsourcing and DORA rules. They argue QTSPs provide specialized services, undergo formal qualification, and face dedicated supervision.1234
How it helps them — This would exempt banks from applying standard outsourcing compliance requirements to QTSP relationships.5
Who loses — Financial regulators lose oversight tools for managing third-party technology risks in digital identity.
Response to: COMMISSION IMPLEMENTING REGULATION (EU) …/... laying down rules for the application of Regulation (EU) No 910/2014 of the European Parliament and of the Council as regards the format and procedures for notification of intention and verification with regard to the initiation of qualified trust services

European Banking Federation Seeks Clarity on Time-Stamp Requirements

13 May 2025
Feedback on — EU regulation on qualified electronic time stamps for digital identity wallets.
Their ask — The federation requests more detailed specification of when qualified electronic time stamping must be used in digital identity wallets. They want this addressed to create a robust and harmonised certification framework.12
How it helps them — This would reduce uncertainty and compliance costs for banks implementing digital identity systems.3
Response to: COMMISSION IMPLEMENTING REGULATION (EU) …/... laying down rules for the application of Regulation (EU) No 910/2014 of the European Parliament and of the Council as regards the binding of date and time to data and establishing the accuracy of the time sources for the provision of qualified electronic time stamps

Banking Industry Urges Stricter Controls on eID Peer Reviews

13 May 2025
Feedback on — EU regulation on procedural arrangements for peer reviews of electronic identification schemes.
Their ask — The associations request stricter oversight of peer review processes to prevent conflicts of interest and ensure transparency. They want decisions to refuse reviewers or withhold information to require clear justification and scrutiny by the Cooperation Group.12
How it helps them — This would prevent regulatory arbitrage and forum shopping by providers and relying parties.3
Who loses — Member states lose flexibility to protect sensitive national security or business information.4
Response to: COMMISSION IMPLEMENTING REGULATION (EU) …/... on laying down rules for the application of Regulation (EU) No 910/2014 of the European Parliament and of the Council as regards procedural arrangements for peer reviews of electronic identification schemes and for cooperation on the organisation of such reviews within the Cooperation Group and repealing Commission Implementing Decision (EU) 2015/296

European Banking Federation Seeks Transparency in Digital Wallet Supervision

13 May 2025
Feedback on — Annual reporting requirements for supervisors of European Digital Identity Wallets.
Their ask — The organization requests public disclosure of key supervisory information including security breaches, non-compliance actions, and fraudulent wallet use. They emphasize the need for harmonized reporting to prevent forum shopping by providers.12
How it helps them — This would create a level playing field and consistent supervision across Member States.34
Who loses — Wallet providers lose ability to exploit regulatory arbitrage between Member States.5
Response to: COMMISSION IMPLEMENTING REGULATION (EU) …/... on laying down rules for the application of Regulation (EU) No 910/2014 of the European Parliament and of the Council as regards the formats and procedures for annual reports by supervisory bodies

Response to Joint communication to the European Parliament and the Council on a comprehensive strategic approach towards India

8 May 2025

Meeting with Arba Kokalari (Member of the European Parliament, Rapporteur) and

30 Apr 2025 · AI in Financial Services

Meeting with Martin Merlin (Director Financial Stability, Financial Services and Capital Markets Union) and BNP PARIBAS

28 Apr 2025 · Exchange of views on the Savings and Investments Union package and other topics

Meeting with Nicolo Brignoli (Cabinet of Commissioner Valdis Dombrovskis) and

22 Apr 2025 · FIDA

Meeting with Jennifer Robertson (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

15 Apr 2025 · Third-country CCP equivalence regime

Meeting with Stéphane Séjourné (Executive Vice-President) and

10 Apr 2025 · Impact of US tariffs

Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs) and

10 Apr 2025 · Impact of US tariffs

Meeting with Jörgen Warborn (Member of the European Parliament, Rapporteur) and DIGITALEUROPE

9 Apr 2025 · Omnibus

Meeting with Leonie Bell (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

31 Mar 2025 · Reporting

Response to Amendments to Taxonomy Delegated Acts

26 Mar 2025

European Banking Federation calls for bottom-up approach to capital markets

7 Mar 2025
Feedback on — EU consultation on Savings and Investments Union to mobilize financing for growth.
Their ask — Banks urge Member States to adopt a 'Capital Markets Mindset' - developing domestic markets through tax incentives and pension reforms rather than EU-wide regulatory solutions. They reject proposals for a new common EU savings product, calling it unnecessary when diverse products already exist. They want simplified disclosure rules, easier securitization, and reduced capital requirements to unlock bank lending capacity.1234
How it helps them — This would reduce banks' capital requirements and compliance costs while preserving their flexibility.567
Who loses — Retail investors lose potential protections from simpler, standardized products with clearer disclosures.89
Response to: Savings and Investments Union

European Banking Federation urges permanent repo market rules

6 Mar 2025
Feedback on — EU regulation on net stable funding ratio treatment for securities financing transactions.
Their ask — The federation requests making permanent the current treatment of short-term reverse repos and unsecured funding with financial customers before the June 2025 deadline. They warn that reverting to Basel standards would reduce repo market size and undermine government bond market making.12
How it helps them — This preserves their profitable repo operations and maintains liquidity sources for banks.34
Who loses — EU member states face higher financing costs and difficulties rolling over sovereign debt.5
Response to: Proposal for a Regulation of the European Parliament and of the Council amending Regulation (EU) No 575/2013 on prudential requirements for credit institutions as regards requirements for reverse-repurchase transactions under the net stable funding ratio

Meeting with Gheorghe Piperea (Member of the European Parliament)

6 Mar 2025 · Insolvency law

Meeting with Arba Kokalari (Member of the European Parliament) and Bureau Européen des Unions de Consommateurs

5 Mar 2025 · Savings and Investments Union

Meeting with Maria Raffaella Assetta (Head of Unit Financial Stability, Financial Services and Capital Markets Union) and

4 Mar 2025 · EU financial services industry associations debrief on EU-UK Financial Regulatory Forum

Meeting with Maria Luís Albuquerque (Commissioner) and

3 Mar 2025 · Exchange with the European Banking Federation on regulatory developments

Meeting with Maria Raffaella Assetta (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

27 Feb 2025 · Participation at the 23rd meeting of EBF International Affairs Steering Group to present the priorities of the EC in relation to, US, UK, India and China.

Meeting with Ton Diepeveen (Member of the European Parliament, Shadow rapporteur)

18 Feb 2025 · Kennismakingsgesprek

Meeting with Fernando Navarrete Rojas (Member of the European Parliament, Rapporteur)

6 Feb 2025 · Euro Digital

Meeting with Larisa Dragomir (Cabinet of Commissioner Maria Luís Albuquerque)

5 Feb 2025 · Exchange with EBF - European Banking Federation on banking related aspects

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

16 Jan 2025 · Commission’s priorities for the upcoming mandate

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

16 Jan 2025 · Exchange of views on the simplification policy.

Meeting with Nicolo Brignoli (Cabinet of Commissioner Valdis Dombrovskis)

16 Jan 2025 · Exchange of views on the simplification policy

Meeting with Emil Radev (Member of the European Parliament, Rapporteur)

14 Jan 2025 · Harmonising certain aspects of insolvency law

Meeting with Maria Raffaella Assetta (Head of Unit Financial Stability, Financial Services and Capital Markets Union) and

9 Jan 2025 · EU-UK Financial Regulatory Forum

Meeting with Anouk Van Brug (Member of the European Parliament)

10 Dec 2024 · General meeting introduction

Meeting with Stéphanie Yon-Courtin (Member of the European Parliament) and

3 Dec 2024 · Savings and Investments Union

Meeting with Gilles Boyer (Member of the European Parliament) and

3 Dec 2024 · CMU

Meeting with Jonás Fernández (Member of the European Parliament)

17 Oct 2024 · Priorities current term

Meeting with René Repasi (Member of the European Parliament) and ACCIS

17 Oct 2024 · Conference - European Court of Justice - Access to requests for preliminary ruling for interested third parties

Meeting with Michalis Hadjipantela (Member of the European Parliament)

2 Oct 2024 · Introductory Meeting with European Banking Federation

Meeting with Nikos Papandreou (Member of the European Parliament, Shadow rapporteur)

25 Sept 2024 · Digital euro

Meeting with Mairead McGuinness (Commissioner) and

10 Sept 2024 · High-level executive roundtable: preventing the circumvention of EU sanctions on sensitive goods.

Meeting with Valdis Dombrovskis (Executive Vice-President) and

10 Sept 2024 · Preventing the circumvention of EU sanctions on sensitive goods

European Banking Federation seeks ATAD-Pillar Two harmonization to reduce burden

9 Sept 2024
Feedback on — Evaluation of EU Anti-Tax Avoidance Directive and its interaction with new rules.
Their ask — The organization requests harmonization of ATAD rules with Pillar Two framework to eliminate regulatory overlap. They argue both directives share the same policy objective but create excessive administrative burdens. They specifically request exemption from CFC rules when Pillar Two applies and exclusion of financial undertakings from interest limitation rules.1234
How it helps them — This would reduce compliance costs from managing two overlapping tax regimes simultaneously.56
Who loses — Tax authorities lose dual safeguards against profit shifting to low-tax jurisdictions.7
Response to: Evaluation of the Anti- Tax Avoidance Directive (ATAD) - Council Directive (EU) 2016/1164 of 12 July 2016 as amended by Council Directive (EU) 2017/952 of 29 May 2017

European Banking Federation seeks flexibility in GDPR enforcement

8 Feb 2024
Feedback on — Review of the General Data Protection Regulation six years after implementation.
Their ask — The federation requests uniform GDPR interpretation across member states, better coordination between data protection and sectoral financial regulations, and preservation of the regulation's risk-based approach. They argue current guidelines are too prescriptive and undermine banks' ability to implement compliance autonomously.123
How it helps them — This would reduce operational complexity and give banks more autonomy in compliance decisions.45
Who loses — Consumers may face weaker data access rights if request timelines are extended.6
Response to: Report on the application of the General Data Protection Regulation to the European Parliament and the Council

Meeting with Mairead McGuinness (Commissioner)

25 Jan 2024 · Retail Investment Strategy Roundtable.

Response to Proposal for a COUNCIL DIRECTIVE on Business in Europe: Framework for Income Taxation (BEFIT)

24 Jan 2024

Meeting with Tove Ernst (Cabinet of Commissioner Stella Kyriakides) and

10 Jan 2024 · Europe’s Beating Cancer Plan; quality of life”

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness)

13 Dec 2023 · code of conduct cancer survivors

Meeting with Ville Niinistö (Member of the European Parliament, Shadow rapporteur)

13 Dec 2023 · Financial Data Access

Response to Administrative burden

1 Dec 2023

Meeting with Maroš Šefčovič (Executive Vice-President) and

30 Nov 2023 · Clean Transition Dialogue on Energy Intensive Industries

Meeting with Frances Fitzgerald (Member of the European Parliament, Shadow rapporteur)

6 Nov 2023 · Insolvency law

European Banking Federation urges gradual approach to financial data sharing

31 Oct 2023
Feedback on — EU regulation extending customer data access rights across financial sectors beyond payments.
Their ask — The federation requests a 48-month implementation timeline instead of 18 months, a gradual staged approach starting with limited data sets, and clear exclusion of derived and inferred data from mandatory sharing. They emphasize that reasonable compensation should cover investments in data infrastructure, not just direct sharing costs.1234
How it helps them — This would protect their proprietary assessment methods and give them compensation for data infrastructure investments.56
Who loses — Financial technology companies lose quick access to bank customer data for innovation purposes.7
Response to: Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on a framework for Financial Data Access and amending Regulations (EU) No 1093/2010, (EU) No 1094/2010, (EU) No 1095/2010 and (EU) 2022/2554

Meeting with Aurore Lalucq (Member of the European Parliament, Rapporteur)

16 Oct 2023 · ESG ratings

Meeting with Rasmus Andresen (Member of the European Parliament, Shadow rapporteur) and

12 Oct 2023 · ESG

Meeting with Marek Belka (Member of the European Parliament, Rapporteur)

25 Sept 2023 · Payment Services Regulation (APA on behalf of MEP)

Meeting with Alin Mituța (Member of the European Parliament, Shadow rapporteur)

21 Sept 2023 · European Digital Identity Framework (eID)

Banking federation urges optional withholding tax relief scheme

18 Sept 2023
Feedback on — EU proposal to streamline withholding tax relief procedures for cross-border investments.
Their ask — The EBF requests that participation as a Certified Financial Intermediary remain optional rather than mandatory, with simplified due diligence requirements and longer reporting timelines. They argue the proposed obligations are "even more burdensome than those currently in application" and want CFIs to be "free to decide for which countries they want to offer this tax relief service."1234
How it helps them — This would reduce their administrative burden and compliance costs significantly.56
Who loses — Cross-border investors lose faster access to withholding tax refunds and relief.7
Response to: Proposal for a COUNCIL DIRECTIVE on Faster and Safer Relief of Excess Withholding Taxes

European Banking Federation Opposes Value-for-Money Rules and Inducement Ban

28 Aug 2023
Feedback on — EU proposal to strengthen retail investor protection in financial product distribution.
Their ask — Banks want the EU to abandon quantitative value-for-money benchmarks that overlook qualitative aspects of advice. They oppose the partial ban on inducements for execution-only services, arguing it resembles a full commission ban. They seek to preserve existing investor protection rules rather than adopt the proposed best-interest principle.123
How it helps them — This would preserve commission-based revenue models and avoid costly compliance systems.45
Who loses — Retail investors lose protections against high-cost products and conflicted advice.6
Response to: 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

Meeting with Mairead McGuinness (Commissioner) and

18 Jul 2023 · Distribution of Retail financial products

European Banking Federation urges mandatory climate disclosures in sustainability reporting

7 Jul 2023
Feedback on — EU standards requiring companies to report on environmental, social and governance factors.
Their ask — Banks want mandatory disclosure of key climate data and environmental information, not voluntary based on materiality assessment. They request removal of materiality assessment for climate indicators, Scope 1-3 emissions, and data needed for their own regulatory reporting. They seek alignment between company reporting requirements and bank disclosure obligations.123
How it helps them — This would provide banks with counterparty climate data needed for their own regulatory compliance.45
Who loses — Companies lose flexibility to omit climate data they consider immaterial to their business.6
Response to: COMMISSION DELEGATED REGULATION (EU) …/... supplementing Directive 2013/34/EU of the European Parliament and of the Council as regards sustainability reporting standards

Meeting with Simon Genevaz (Cabinet of Executive Vice-President Margrethe Vestager)

13 Jun 2023 · digital euro

Meeting with Alfred Sant (Member of the European Parliament, Rapporteur) and Afore Consulting

6 Jun 2023 · Listing Act

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

23 May 2023 · Preparation of Commissioner McGuinness’s speech at the EBF conference of 1 June 2023

European Banking Federation demands taxonomy reporting delays and template fixes

3 May 2023
Feedback on — EU regulation establishing classification system for environmentally sustainable economic activities across four objectives.
Their ask — The federation requests a one-year delay for financial institutions' eligibility reporting until 2025, and at least one year phase-in for alignment reporting on amended climate activities. They demand corrections to contradictory timing provisions and templates that lack necessary formulas and rows.1234
How it helps them — This would allow banks to base calculations on actual counterparty disclosures rather than problematic estimates.56
Who loses — Investors and policymakers lose timely transparency on banks' sustainable finance activities and progress.
Response to: COMMISSION DELEGATED REGULATION (EU) …/... supplementing Regulation (EU) 2020/852 of the European Parliament and of the Council by establishing the technical screening criteria for determining the conditions under which an economic activity qualifies as contributing substantially to the sustainable use and protection of water and marine resources, to the transition to a circular economy, to pollution prevention and control, or to the protection and restoration of biodiversity and ecosystems and for determining whether that economic activity causes no significant harm to any of the other environmental objectives and amending Delegated Regulation (EU) 2021/2178 as regards specific public disclosures for those economic activities

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness), Patricia Reilly (Cabinet of Commissioner Mairead Mcguinness)

3 May 2023 · open finance

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

3 May 2023 · EMIR

Response to Proposal for a COUNCIL DIRECTIVE amending Directive 2011/16/EU on administrative cooperation in the field of taxation

30 Mar 2023

Meeting with Mairead McGuinness (Commissioner) and

28 Mar 2023 · Round-Table on Digital Euro (with EVP Dombrovskis and DG FISMA)

Meeting with Mairead McGuinness (Commissioner) and

22 Mar 2023 · Current economic conditions, banking package, crisis management, clearing, retail investment strategy, digital Euro

European Banking Federation Opposes Forced CCP Exposure Reduction Plans

21 Mar 2023
Feedback on — EU proposal to address concentration risk towards central counterparties and clearing.
Their ask — The organization requests reconsideration of new obligations requiring banks to develop plans and set targets for reducing concentration risk towards third-country CCPs. They argue supervisors already have adequate powers and the new requirements are disproportionate and intrusive.123
How it helps them — This would prevent regulatory interference with their core business activities and client relationships.4
Who loses — EU supervisors lose new tools to reduce risky concentration in non-EU clearing houses.5
Response to: Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Directives 2009/65/EU, 2013/36/EU and (EU) 2019/2034 as regards the treatment of concentration risk towards central counterparties and the counterparty risk on centrally cleared derivative transactions

European Banking Federation seeks secured creditor protections in insolvency reform

14 Mar 2023
Feedback on — Proposed EU directive harmonizing national insolvency laws to support Capital Markets Union.
Their ask — The federation demands protections for secured creditors in pre-pack sales and avoidance actions. They want exemptions for financial contracts from stay provisions and termination restrictions. The proposal should clarify that secured creditors must approve asset sales and maintain priority claims.123
How it helps them — This would protect their loan recovery rates and reduce legal uncertainty in cross-border lending.45
Who loses — Unsecured creditors and employees would face lower recovery rates as secured banks maintain priority.6
Response to: Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL harmonising certain aspects of insolvency law

Meeting with Marek Belka (Member of the European Parliament, Shadow rapporteur)

27 Feb 2023 · Instant Payments

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

1 Feb 2023 · retail investment strategy

Meeting with Agnieszka Drzewoska (Cabinet of Commissioner Mairead Mcguinness) and

1 Feb 2023 · Retail Investment Strategy

Meeting with Ivars Ijabs (Member of the European Parliament, Shadow rapporteur) and Deutsche Bank AG

31 Jan 2023 · Instant payment regulation

European Banking Federation Seeks Market-Driven Approach to Instant Payments

21 Dec 2022
Feedback on — EU regulation mandating instant euro credit transfers across all payment service providers.
Their ask — The federation opposes mandatory instant payment offerings through all channels, arguing banks should maintain freedom to determine their product offerings. They request legal requirements be limited to mandating sending for single payments through online channels and mandating reachability. They strongly object to price regulation, arguing instant payments have higher costs than regular transfers and competition should determine pricing.1234
How it helps them — Banks could avoid mandatory 24/7 infrastructure investments and recover higher operational costs through differentiated pricing.56
Who loses — Consumers and small businesses lose guaranteed access to instant payments at affordable prices.7
Response to: Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Regulations (EU) No 260/2012 and (EU) 2021/1230 as regards instant credit transfers in euro

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness)

16 Dec 2022 · energy crisis, Market Correction Mechamism, EMIR review, CCPs

Meeting with Hanna Jahns (Cabinet of Commissioner Johannes Hahn)

14 Dec 2022 · EU banking regulatory and supervisory framework

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

23 Nov 2022 · Digital euro, EU Sustainability Standards

Meeting with Frances Fitzgerald (Member of the European Parliament, Shadow rapporteur)

15 Nov 2022 · European Single Access Points

Meeting with Anthony Agotha (Cabinet of Executive Vice-President Frans Timmermans)

9 Nov 2022 · Green Deal/COP27 presentation

Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur) and

7 Nov 2022 · Corporate Sustainability Due Diligence

Meeting with Karen Melchior (Member of the European Parliament, Shadow rapporteur)

21 Oct 2022 · Data Act

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

21 Oct 2022 · EBF presented banking sector's main concerns on digital euro and in particular impacts on financial stability, payment systems, AML/privacy issues.

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

21 Oct 2022 · Digital Euro

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness) and

21 Oct 2022 · digital euro

Meeting with Katherine Power (Cabinet of Commissioner Mairead Mcguinness)

13 Oct 2022 · Sustainable Finance

Meeting with Alfred Sant (Member of the European Parliament)

12 Oct 2022 · Banking package

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness), Katherine Power (Cabinet of Commissioner Mairead Mcguinness) and BNP PARIBAS

21 Sept 2022 · Energy market liquidity measures

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

21 Sept 2022 · BNP Paribas views on potential price caps and liquidity measures in the context of the energy crisis

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

21 Sept 2022 · energy market liquidity measures

Meeting with Dārta Tentere (Cabinet of Commissioner Mairead Mcguinness)

6 Sept 2022 · Sustainable finance

Banking Federation Urges Voluntary Open Finance Framework

2 Aug 2022
Feedback on — EU proposal to extend data sharing beyond payments to wider financial sectors.
Their ask — The federation requests a voluntary data-sharing framework based on market needs rather than mandatory access rights. They want provisions covering consumer protection, liability, compensation, and technical standards developed through market-driven initiatives. They argue no new mandatory data access rights should be introduced until other economic sectors have comparable frameworks.123
How it helps them — This would prevent them bearing infrastructure costs without compensation while competitors access their data.456
Who loses — Third-party fintech providers lose mandated free access to bank-held customer data.7
Response to: REGULATION/DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on an Open Finance Framework

Banking Federation Seeks Removal of Withdrawal Button from Distance-Selling Rules

8 Jul 2022
Feedback on — EU reform of consumer protection rules for financial services sold remotely.
Their ask — The EBF requests removal of the mandatory withdrawal button, elimination of the one-day interval before contract conclusion, and clarification of how the directive interacts with product-specific legislation. They want to limit pre-contractual information to essential elements only.1234
How it helps them — This would avoid high IT costs and operational changes for banks.56
Who loses — Consumers lose clearer access to withdrawal rights and additional safeguards for distance purchases.7
Response to: Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Directive 2011/83/EU concerning financial services contracts concluded at a distance and repealing Directive 2002/65/EC

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

7 Jul 2022 · Topic: Polish loans in foreign currency (CHF) and the UCTD Directive. Eu Commission made it clear that we do not interfere in cases before the ECJ and with the SJ work in this regard.

Meeting with Alin Mituța (Member of the European Parliament, Shadow rapporteur) and

6 Jul 2022 · Data Act

Meeting with Joachim Schuster (Member of the European Parliament)

28 Jun 2022 · Banking package

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

15 Jun 2022 · CRR

European Banking Federation seeks uniform EU digital consumer rules

13 Jun 2022
Feedback on — Review of EU consumer protection directives for digital fairness and online markets.
Their ask — The federation requests full harmonization across EU member states to prevent national gold-plating that fragments the market. They want financial products exempted from general rules and emphasis on quality information over quantity.123
How it helps them — This would let banks offer identical products across Europe without compliance fragmentation costs.4
Who loses — Member states lose ability to impose stricter national consumer protections than EU minimums.5
Response to: Fitness Check of EU consumer law on digital fairness - Directives 2005/29/EC, 2011/83/EU, 93/13/EEC

European Banking Federation urges penalties over buy-ins for settlement discipline

26 May 2022
Feedback on — EU review of Central Securities Depositories Regulation on settlement efficiency and cross-border services.
Their ask — The federation supports prioritizing cash penalties over mandatory buy-ins to reduce settlement failures. They request clearer definitions of 'trading party', a centralized ESMA database for reference data, and ensuring buy-in obligations rest with trading parties rather than intermediaries. They emphasize mandatory buy-ins are disproportionate tools that risk reducing market liquidity and increasing costs.1234
How it helps them — This would reduce operational complexity and avoid undue financial risks on intermediaries for trading outcomes beyond their control.56
Who loses — Buyers lose stronger protections against settlement failures if buy-in mechanisms are weakened or delayed.7
Response to: Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Regulation (EU) No 909/2014 as regards settlement discipline, cross-border provision of services, supervisory cooperation, provision of banking-type ancillary services and requirements for third-country central securities depositories

European banks seek clarity on due diligence scope

20 May 2022
Feedback on — EU directive on corporate sustainability due diligence across value chains.
Their ask — The banking federation requests clearer definitions of value chain obligations, exemption of subsidiaries, and alignment with existing UN and OECD standards. They want due diligence requirements limited to credit and lending services, excluding other financial products. They strongly oppose civil liability provisions.1234
How it helps them — This would reduce legal uncertainty and avoid retrospective obligations on existing contracts.56
Who loses — Affected communities lose strong remedies as banks avoid liability for client impacts.7
Response to: Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on Corporate Sustainability Due Diligence and amending Directive (EU) 2019/1937

Meeting with Danuta Maria Hübner (Member of the European Parliament)

10 May 2022 · Digital Euro

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

10 May 2022 · EU Banking Package 2021

European Banking Federation Questions Need for New Shell Entity Rules

6 Apr 2022
Feedback on — EU directive targeting misuse of shell entities for tax avoidance purposes.
Their ask — The federation questions whether new rules are needed given existing anti-tax avoidance measures. They request broader exclusions for banking groups and their subsidiaries to avoid unnecessary compliance costs. They want harmonized EU-wide interpretation to prevent chaotic application across member states.123
How it helps them — This would allow banks to avoid substantial compliance costs already imposed by recent reporting rules.45
Who loses — Tax authorities lose stronger tools to identify and prevent cross-border tax avoidance schemes.
Response to: Proposal for a COUNCIL DIRECTIVE laying down rules to prevent the misuse of shell entities for tax purposes and amending Directive 2011/16/EU

Response to Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending certain Directives as regards the establishment and functioning of the European single access point

29 Mar 2022

Response to Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending certain Regulations as regards the establishment and functioning of the European single access point

29 Mar 2022

Banking Federation Urges Phased EU Data Platform Rollout

29 Mar 2022
Feedback on — EU proposal to create a single access point for company financial and sustainability data.
Their ask — The federation requests a gradual implementation prioritizing sustainability data over a comprehensive launch. They want at least one year between technical standards publication and reporting requirements. They emphasize maintaining the 'file only once' principle to avoid duplicating existing reporting obligations.123
How it helps them — This would reduce the substantial operational costs and technical work needed for data standardization.45
Who loses — Investors and consumers lose immediate access to comprehensive comparable financial data across all sectors.6
Response to: Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL establishing a European single access point providing centralised access to publicly available information of relevance to financial services, capital markets and sustainability

Meeting with Luis Garicano (Member of the European Parliament, Rapporteur)

29 Mar 2022 · Conference on anti-money laundering with stakeholders

Meeting with Paul Tang (Member of the European Parliament, Rapporteur)

15 Mar 2022 · Meeting on Anti-Money Laundering Package

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

15 Mar 2022 · EU Banking Package 2021 (EBF breakfast workshop)

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

10 Mar 2022 · Banking package, Banking union, CMU

Meeting with Petar Vitanov (Member of the European Parliament, Shadow rapporteur) and Council of Bars and Law Societies of Europe

9 Mar 2022 · AI Act

Meeting with Gilles Boyer (Member of the European Parliament, Shadow rapporteur) and Association Française des Entreprises Privées / French Association of Large Companies

9 Mar 2022 · EUGB (staff)

Meeting with Alin Mituța (Member of the European Parliament, Shadow rapporteur)

4 Mar 2022 · European Digital Identity proposal (eID)

Meeting with Nicolo Brignoli (Cabinet of Commissioner Mairead Mcguinness)

22 Feb 2022 · Instant Payments.

Meeting with Pedro Marques (Member of the European Parliament, Shadow rapporteur)

11 Feb 2022 · AMLA

Meeting with Billy Kelleher (Member of the European Parliament, Rapporteur)

11 Feb 2022 · DORA

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

1 Feb 2022 · EU Banking Package 2021

Meeting with Lucia Bonova (Cabinet of Executive Vice-President Margrethe Vestager), Werner Stengg (Cabinet of Executive Vice-President Margrethe Vestager)

1 Feb 2022 · Data Act

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness)

28 Jan 2022 · data economy, digital finance

European Banking Federation Opposes New Capital Deduction Rules

20 Jan 2022
Feedback on — Implementation of Basel III prudential standards and resolution requirements for banks.
Their ask — The EBF requests limiting deductions to eligible liabilities only, excluding own funds until a full impact assessment is conducted. They want adequate implementation time to avoid breaching MREL requirements. They argue the current proposal contradicts existing capital requirements and lacks proper impact assessment.1234
How it helps them — This would prevent intermediate parent entities from breaching requirements and maintain lending capacity.567
Who loses — Regulators lose stricter capital buffers designed to ensure bank resolvability during crises.89
Response to: Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Regulation (EU) No 575/2013 and Directive 2014/59/EU as regards the prudential treatment of global systemically important institution groups with a multiple point of entry resolution strategy and a methodology for the indirect subscription of instruments eligible for meeting the minimum requirement for own funds and eligible liabilities

European Banking Federation warns Basel III impact understated

17 Jan 2022
Feedback on — Implementation of Basel III banking standards in EU capital requirements regulation.
Their ask — The federation argues the true capital impact is significantly higher than the Commission's 6-8% estimate, requesting the output floor be applied only at consolidated level and permanent solutions for unrated corporates and real estate exposures. They want numerous technical standards clearly framed to prevent scope creep beyond Basel Committee intent.123
How it helps them — This would preserve their current capital buffers and lending capacity without raising additional capital.45
Who loses — Financial system stability loses if banks maintain lower capital buffers than intended by Basel standards.
Response to: Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Regulation (EU) No 575/2013 as regards requirements for credit risk, credit valuation adjustment risk, operational risk, market risk and the output floor

Banking Federation Backs Crypto AML Rules, Seeks Implementation Delay

29 Nov 2021
Feedback on — New EU regulation extending anti-money laundering rules to crypto-asset transfers.
Their ask — The organization supports extending AML rules to crypto providers to achieve a level playing field. However, they request a longer implementation period and clearer guidance on technical compliance, particularly for interactions with unhosted wallets and decentralized systems.123
How it helps them — This would give banks and crypto providers more time to develop compatible technical solutions.45
Who loses — Financial crime enforcement loses immediate compliance from crypto providers operating in decentralized systems.6
Response to: Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on information accompanying transfers of funds and certain crypto-assets (recast)

Banking Federation Calls for Risk-Based AML Authority Selection

29 Nov 2021
Feedback on — New EU regulation establishing an Anti-Money Laundering and Counter-Terrorism Financing Authority.
Their ask — The organization wants AMLA to select supervised entities based on actual risk rather than size or geographic spread. They request extending AMLA's scope to non-financial sectors and avoiding duplicated supervision and fees between AMLA and national authorities.1234
How it helps them — This would prevent large banks from automatic selection while smaller high-risk entities escape scrutiny.56
Who loses — Smaller non-bank financial firms and non-financial sectors face lighter supervision under current proposal.7
Response to: Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL establishing the Authority for Anti-Money Laundering and Countering the Financing of Terrorism and amending Regulations (EU) No 1093/2010, (EU) 1094/2010, (EU) 1095/2010

Meeting with Valdis Dombrovskis (Executive Vice-President)

26 Nov 2021 · Basel III implementation, sustainable finance, digital finance

Banking Federation Seeks Intelligence-Led AML Approach Over Tick-Box Compliance

18 Nov 2021
Feedback on — EU directive on preventing money laundering and terrorist financing through the financial system.
Their ask — The EBF calls for a paradigm shift away from bureaucratic tick-box compliance that generates irrelevant data. They want clearer risk assessment criteria, strengthened beneficial owner registers with verified data, and enhanced information sharing leveraging new technologies. They also seek more frequent feedback from Financial Intelligence Units on suspicious activity reports.1234
How it helps them — This would reduce compliance workload and allow banks to focus resources on genuine high-risk cases.56
Who loses — Financial Intelligence Units lose the massive data flows they currently receive from defensive over-reporting.7
Response to: Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on the mechanisms to be put in place by the Member States for the prevention of the use of the financial system for the purposes of money laundering or terrorist financing and repealing Directive (EU) 2015/849

European Banking Federation urges shift from tick-box AML compliance

18 Nov 2021
Feedback on — New EU regulation on preventing money laundering and terrorist financing.
Their ask — The federation requests moving away from rigid, prescriptive rules toward a flexible, intelligence-led approach. They want less standardization that allows Member States to add requirements, arguing this reintroduces fragmentation. They seek permission to apply enhanced due diligence only for high-risk cases, not increased-risk ones, and want flexibility in governance structures rather than mandatory two-tier compliance systems.1234
How it helps them — This would reduce compliance burdens and allow banks to focus resources on detecting actual criminal activity.5
Who loses — Financial intelligence units lose standardized data flows needed to identify criminal patterns across jurisdictions.6
Response to: Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing

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

30 Sept 2021 · Basel III

European Banking Federation Demands 12-Month PRIIPs Implementation Period

9 Sept 2021
Feedback on — New EU rules on packaged retail investment product disclosure and investor communication.
Their ask — The organization requests a 12-month implementation period from adoption of new technical standards, instead of the proposed shortened timeline. They argue the current timeline cuts implementation by over 2 months and is insufficient for complex changes involving multiple departments, IT systems, data gathering, and coordination across the investment value chain.123
How it helps them — This avoids substantial compliance burden and prevents forced suspension of product distribution.45
Who loses — Consumers face delayed access to improved, clearer investment product information and disclosures.
Response to: Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Regulation (EU) No 1286/2014 as regards the extension of the transitional arrangement for management companies, investment companies and persons advising on, or selling, units of undertakings for collective investment in transferable securities (UCITS) and non-UCITS

European Banking Federation Opposes Consumer Credit Directive Expansion

2 Sept 2021
Feedback on — Review of EU consumer credit rules covering scope, information requirements and creditworthiness assessment.
Their ask — Banks want proportional rules that don't extend burdensome requirements to all loan sizes, oppose interest rate caps, seek simplified digital-age information requirements, and want limits on creditworthiness assessment safeguards. They argue the proposal creates administrative burden without increasing consumer protection.1234
How it helps them — Banks would avoid unreasonable administrative costs for small loans and maintain pricing flexibility.56
Who loses — Consumers needing small loans lose access as banks stop offering uneconomical products.78
Response to: Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on consumer credits

Banking Federation Backs Swift CHF LIBOR Replacement Implementation

31 Aug 2021
Feedback on — Commission regulation designating statutory replacement rates for CHF LIBOR benchmark settings.
Their ask — The EBF urges immediate adoption of the statutory replacement regulation to prevent market disruption. They request the 6-month and 12-month tenors use 3-month SARON rates instead of longer observation periods. They also want information requirements limited to consumers only, with flexible timing and formats.1234
How it helps them — This avoids hedging mismatches and accounting challenges while providing flexibility on client communications.56
Who loses — Non-consumer clients lose statutory notification rights about benchmark changes affecting their contracts.7
Response to: COMMISSION IMPLEMENTING REGULATION (EU) …/... on the designation of a statutory replacement for certain settings of CHF LIBOR

European Banking Federation Backs Statutory EONIA Replacement Rate

31 Aug 2021
Feedback on — Designation of statutory replacements for EONIA benchmark ceasing publication January 2022.
Their ask — The organization fully supports designating a statutory replacement rate for EONIA to provide legal certainty. They request clarifications that the tool won't displace existing bilateral agreements and suggest replacing 'Credit Support Annexes' with 'Collateral Agreements' for broader clarity.123
How it helps them — This eliminates legal uncertainty for banks whose clients failed to renegotiate contracts before deadline.456
Response to: COMMISSION IMPLEMENTING REGULATION (EU) …/... on the designation of a replacement for the benchmark European overnight index average in contracts and financial instruments as referred to in Article 23a of Regulation (EU) 2016/1011 of the European Parliament and of the Council

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

22 Jul 2021 · Exchange about the NPL Advisory Panel

Meeting with Katherine Power (Cabinet of Commissioner Mairead Mcguinness)

15 Jul 2021 · Sustainable Finance Introductory meeting

Response to Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Directive 2013/34/EU, Directive 2004/109/EC, Directive 2006/43/EC and Regulation (EU) No 537/2014, as regards corporate sustainability reporting

14 Jul 2021

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

6 Jul 2021 · COVID 19 response

European Banking Federation urges cross-sectoral data portability expansion

25 Jun 2021
Feedback on — EU regulation on data access, use, and fairness in the data economy.
Their ask — The organization requests that enhanced data portability rights extend beyond IoT devices to all sectors including telecommunications, utilities, e-commerce, and mobility services. They argue the current narrow scope creates market asymmetries and barriers.123
How it helps them — This would allow banks to leverage existing PSD2 interfaces and expand services like green financing and personalized financial advice.45
Who loses — Other sectors excluded from standard-setting would face technical barriers and competitive disadvantages in data sharing.6
Response to: Regulation establishing a framework for the use of data in the EU

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

28 May 2021 · Basel III implementation

Banking Federation Seeks Market-Led Approach to EU Instant Payments

7 Apr 2021
Feedback on — EU initiative to assess legislative and non-legislative measures for pan-European instant payments adoption.
Their ask — The federation urges a market-driven approach to instant payments adoption rather than mandatory regulation. They request sufficient implementation time if adherence is mandated, and call for a stable regulatory environment supporting value-added products. They oppose price regulation for instant payments.123
How it helps them — This would avoid mandatory compliance costs and preserve banks' ability to charge market rates for instant payments.456
Who loses — Consumers and merchants lose potential cost savings from regulated instant payment pricing and mandatory adoption.7
Response to: Initiative on instant payments in the EU

European Banking Federation Demands CSDR Buy-In Rules Be Made Optional

3 Apr 2021
Feedback on — EU review of central securities depositories rules and cross-border settlement services.
Their ask — Banks want mandatory buy-in requirements for non-CCP transactions changed to optional rights. They seek clarification that buy-in obligations don't apply to retail clients and want adequate implementation time for system changes.123
How it helps them — This would avoid operational disruption and maintain European market access for international investors.4
Who loses — Market participants facing settlement failures lose automatic enforcement mechanisms for timely delivery.
Response to: Commission proposal for a Regulation amending Regulation (EU) No 909/2014 of the European Parliament and of the Council of 23 July 2014 on improving securities settlement in the European Union and on central securities depositories and amending Directives 98/26/EC and 2014/65/EU and Regulation (EU) No 236/2012 (CSDR)

Meeting with Mairead McGuinness (Commissioner)

22 Mar 2021 · Introductory Meeting, Covid Recovery, Basel 111

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

23 Feb 2021 · Introductory Call - Stakeholders' Roundtable

Banking Federation Seeks Delay and Flexibility in Digital Resilience Rules

15 Feb 2021
Feedback on — New EU regulation on digital operational resilience for financial sector institutions.
Their ask — The organization requests DORA adopt a risk-based approach with proportionality principles, harmonize ICT incident reporting, and provide flexible implementation timelines. They argue the current one-year implementation period is unrealistic while regulatory technical standards will take 1-3 years to develop. The federation calls for alignment with existing EBA guidelines rather than creating new requirements.12345
How it helps them — This would reduce compliance costs and avoid duplicating existing risk management processes already implemented under EBA guidelines.678
Who loses — Innovation suffers as banks lose access to non-EU critical technology providers and state-of-the-art solutions.91011
Response to: Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on digital operational resilience for the financial sector and amending Regulations (EC) No 1060/2009, (EU) No 648/2012, (EU) No 600/2014 and (EU) No 909/2014

Response to Proposal for a Council Directive on a ‘Digital Levy’

11 Feb 2021

Banking Federation Calls for Broader Data Access Rights

1 Feb 2021
Feedback on — EU framework for data governance, data sharing intermediaries, and common European data spaces.
Their ask — The organization requests stronger measures to increase cross-sectoral data access in the upcoming Data Act, enhanced data portability rights, and permanent industry participation in the European Data Innovation Board. They want data intermediaries to remain optional rather than mandatory for data sharing.1234
How it helps them — This would give banks direct access to customer data without mandatory intermediaries.56
Who loses — Data intermediaries lose their potential role as gatekeepers for personal data flows.7
Response to: Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on European data governance (Data Governance Act)

European Banking Federation seeks level playing field in crypto regulation

11 Jan 2021
Feedback on — New EU regulation establishing requirements for crypto-asset issuance and service provision.
Their ask — The federation requests clearer definitions of crypto-asset categories, consistent supervision frameworks, and alignment with existing financial services rules. They want clarification on outsourcing requirements, liability rules, and transitional periods to avoid regulatory fragmentation.12345
How it helps them — This would allow banks to offer new crypto services under familiar rules.67
Response to: Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on Markets in Crypto-assets, and amending Directive (EU) 2019/1937

European Banking Federation Urges Crypto Tax Rules Align with Existing Framework

20 Dec 2020
Feedback on — EU proposal to extend tax information exchange rules to cover crypto-assets and e-money.
Their ask — The federation wants crypto-asset tax reporting built on the existing DAC 2 framework using definitions from the Markets in Crypto-assets regulation. They advocate applying the principle 'same services, same risks, same rules' and request that reporting be based on readily available objective data using simple valuation methods.1234
How it helps them — This would allow banks to use existing systems rather than building new infrastructure.56
Who loses — Tax authorities lose comprehensive coverage as cold wallet holdings escape reporting requirements.78
Response to: Proposal for a Council Directive amending Directive 2011/16/EU as regards measures to strengthen existing rules and expand the exchange of information framework in the field of taxation to include crypto-assets and e-money.

Banking Federation Urges Caution on EU Insolvency Harmonisation

9 Dec 2020
Feedback on — EU initiative to harmonize substantive corporate insolvency laws across member states.
Their ask — The organization requests principles and best practices rather than binding legislation. They want harmonization focused on achieving better economic outcomes like recovery rates and judicial costs. Member states should retain flexibility to adopt solutions fitting their legal frameworks.123
How it helps them — This would avoid rigid rules that don't fit their lending practices across diverse national systems.45
Who loses — Investors lose stronger cross-border protections and predictability in insolvency outcomes.6
Response to: Initiative to increase the convergence of substantive corporate (non-bank) insolvency laws

Response to Proposal for a Directive of the European Parliament and of the Council amending Directive 2014/59/EU (BRRD)

8 Dec 2020

Meeting with Mairead McGuinness (Commissioner)

20 Nov 2020 · Basel 3 Covid Response in Banking.

Meeting with Andrea Nahles (Cabinet of Commissioner Nicolas Schmit) and

19 Oct 2020 · Social dialogue

Banking Federation Seeks Broad Scope for Benchmark Replacement Rules

29 Sept 2020
Feedback on — EU regulation on replacing financial benchmarks that cease to exist or become unreliable.
Their ask — The federation wants the broadest possible scope for statutory replacement rates, covering all agreements referencing affected benchmarks. They request that bilateral agreements between parties take precedence over statutory replacements. They also want all foreign exchange spot rates exempted from regulation.123
How it helps them — This protects banks' existing bilateral agreements and avoids forcing discontinuation of foreign exchange transactions.4
Who loses — Regulatory oversight is weakened when bilateral agreements override statutory protections for market stability.
Response to: Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Regulation (EU) 2016/1011 as regards the exemption of certain third country foreign exchange benchmarks and the designation of replacement benchmarks for certain benchmarks in cessation

Banking Federation Urges Wider Research Bundling Reform

11 Sept 2020
Feedback on — EU proposal to ease funding for investment research on small companies and bonds.
Their ask — The federation requests extension of the bundling regime to all companies, not just small and mid-caps. They want simplified conditions and clearer rules on calculations and record-keeping. They argue current requirements create burdensome duplicate procedures.123
How it helps them — This would reduce administrative burden and eliminate duplicate compliance procedures for research payments.45
Response to: 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

European Banking Federation opposes new AI-specific legislation

10 Sept 2020
Feedback on — EU proposal to regulate artificial intelligence systems and ensure trustworthy AI uptake.
Their ask — The federation opposes new AI-specific legislation, preferring guidance from authorities on applying existing rules. They warn that prescriptive regulation could harm competitiveness and recommend technology-neutral approaches that avoid duplication with current financial sector regulation.123
How it helps them — This would avoid additional compliance burdens and preserve banks' ability to innovate with AI.45
Who loses — Consumers lose stronger safeguards against AI systems not covered by existing financial regulation.
Response to: Proposal for a Regulation of the European Parliament and the Council laying down requirements for Artificial Intelligence

Response to Commission Delegated Regulation 2021/XXX of XXX 2021 supplementing Regulation 2020/XXX of the European Parliament and of the Council on the establishment of a framework to facilitate sustainable investment, and amending Regulation (EU) 2019/2088

8 Sept 2020

Response to Revision of Directive (EU) 2016/1148 concerning measures for a high common level of security of network and information systems across the Union (NIS Directive)

10 Aug 2020

Banking Federation Demands Cross-Sector Data Sharing in EU Data Spaces

30 Jul 2020
Feedback on — EU legislative framework for governance of common European data spaces and public data sharing.
Their ask — The federation requests that data spaces enable cross-sector data sharing, not just within sectors. They want voluntary participation in consent forms and involvement in any governance structure. They emphasize standardization should leverage existing industry mechanisms.123
How it helps them — This would let banks access customer data from other sectors for faster credit assessments.4
Who loses — Platform users and consumers lose control as banks gain easier access to their commercial data.5
Response to: Legislative framework for the governance of common European data spaces

Banking Federation Seeks Delay for ESG Investment Rules

6 Jul 2020
Feedback on — Integration of sustainability preferences into investment firm requirements under MiFID II.
Their ask — The federation requests extended implementation deadlines and clarification of regulatory definitions. They argue sustainability preferences should reference only Articles 8 and 9 of existing regulations without additional criteria. They want explicit confirmation that existing contracts don't require reassessment.123
How it helps them — This would reduce implementation costs and give banks more time to update IT systems.45
Who loses — Investors seeking sustainable options lose immediate access to clear ESG product information.6
Response to: COMMISSION DELEGATED REGULATION (EU) …/... amending Delegated Regulation (EU) 2017/565 as regards the integration of sustainability factors, risks and preferences into certain organisational requirements and operating conditions for investment firms

European Banking Federation Seeks Delay for Sustainability Rules

6 Jul 2020
Feedback on — EU rules integrating sustainability factors into MiFID II investment advice and product governance.
Their ask — The federation requests more implementation time and clearer definitions of sustainability preferences. They argue current timelines are insufficient given material uncertainties and the need to adapt IT infrastructure. They want flexibility to distribute non-ESG products to clients with ESG preferences for portfolio diversification.1234
How it helps them — This would reduce compliance costs and give banks more time to update internal procedures and systems.56
Who loses — Sustainable investment advocates lose faster implementation of transparency rules for ESG products.7
Response to: COMMISSION DELEGATED DIRECTIVE (EU) .../… amending Delegated Directive (EU) 2017/593 as regards the integration of sustainability factors and preferences into the product governance obligations

European Banking Federation demands data portability from Big Tech platforms

30 Jun 2020
Feedback on — EU regulation targeting large online platforms acting as gatekeepers in digital markets.
Their ask — The federation wants mandatory data portability obligations for large platforms, allowing users to transfer their data to competing firms through standardized interfaces. They seek ex-ante rules addressing platforms' gatekeeping control over data and technical infrastructure like mobile payment systems.12
How it helps them — This would let banks compete with BigTech firms entering financial services using customer data.34
Who loses — Large platforms lose exclusive control over user data and technical infrastructure advantages.56
Response to: Digital Services Act package ex ante regulatory instrument for very large online platforms with significant network effects acting as gate-keepers in the European Union’s internal market

Meeting with Valdis Dombrovskis (Executive Vice-President) and

28 May 2020 · COVID-19 relief measures

Response to Communication from the Commission – Towards a new comprehensive approach to preventing and combating money laundering and terrorism financing

11 Mar 2020

Response to Proposal for a Regulation as regards disclosure of non-financial information by certain undertakings and groups

27 Feb 2020

Meeting with Valdis Dombrovskis (Executive Vice-President) and

19 Feb 2020 · Basel III, Banking Union, Anti-money laundering, Payments

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

14 Mar 2019 · Speech on Capital Markets Union at EBF Steering Committee for Financing Growth

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

14 Jan 2019 · Sustainable Finance

European Banking Federation Urges Digital-First Rules for Financial Services

3 Jan 2019
Feedback on — Review of EU rules governing distance marketing of consumer financial services.
Their ask — The EBF wants updated rules that don't hinder digital banking while ensuring all financial providers face equal consumer protection standards. They seek adapted disclosure mechanisms for digital channels and harmonized rules for electronic contracts across borders.123
How it helps them — This would remove barriers to end-to-end digital banking and enable cross-border mobile sales.456
Who loses — Consumers may face weaker protections if new digital providers avoid stringent disclosure requirements.78
Response to: Evaluation of Directive 2002/65/EC of the European Parliament and of the Council of 23 September 2002 concerning the distance marketing of consumer financial services

Meeting with Günther Oettinger (Commissioner)

21 Sept 2018 · Economic situation and outlook in Greece

Meeting with Andrus Ansip (Vice-President) and

20 Sept 2018 · GDPR, privacy shield, e-privacy

Banking Federation Calls for Proportionality in Consumer Credit Rules

26 Jul 2018
Feedback on — EU evaluation of the Consumer Credit Directive covering lending standards and consumer protections.
Their ask — The federation urges proportionality in creditworthiness assessments, avoiding information overload in disclosures, and maintaining distinctions between consumer credit and real estate loans. They emphasize adapting rules for digital lending while ensuring level playing field for all providers.1234
How it helps them — This would allow them flexibility to tailor lending requirements to local markets and loan types.56
Who loses — Consumers may face weaker protections if proportionality allows lighter checks on smaller loans.7
Response to: Evaluation of Directive 2008/48/EC of the European Parliament and the Council of 23 April 2008 on credit agreements for consumers and repealing Council Directive 87/102/EEC

Meeting with Valdis Dombrovskis (Vice-President) and

20 Jul 2018 · implementation of the PSD2 and related RTS

Meeting with Eduard Hulicius (Cabinet of Commissioner Věra Jourová)

18 Jul 2018 · New deal for Consumers

Response to Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Directive (EU) 2017/1132 as regards the use of digital tools and processes in company law

9 Jul 2018

Meeting with Olivier Guersent (Director-General Financial Stability, Financial Services and Capital Markets Union)

14 May 2018 · Brexit

European Banking Federation seeks flexible shareholder rights implementation timelines

9 May 2018
Feedback on — Implementation requirements for the EU Shareholder Rights Directive regarding information transmission.
Their ask — The EBF requests flexible timelines for information transmission, exemptions from same-day requirements for paper-based communications, and alignment with existing market standards. They emphasize the need to avoid prescriptive formats that contradict ISO standards and warn that the proposed deadlines create unnecessary operational risk.123
How it helps them — This would reduce compliance costs and allow banks to maintain existing efficient processes.45
Who loses — Shareholders may experience delays in exercising voting rights if flexibility reduces information flow speed.6
Response to: COMMISSION IMPLEMENTING REGULATION (EU) …/... laying down minimum requirements implementing the provisions of Directive 2007/36/EC of the European Parliament and of the Council as regards shareholder identification, the transmission of information and the facilitation of the exercise of shareholders rights

Meeting with Carl-Christian Buhr (Cabinet of Commissioner Mariya Gabriel)

17 Apr 2018 · Cybersecurity, blockchain, data, cloud

Response to COMMISSION DELEGATED REGULATION (EU) …/... amending Delegated Regulation (EU) 2015/61 of 10 October 2014 to supplement Regulation (EU) No 575/2013 of the European Parliament and the Council with regard to liquidity coverage requirement for Credit Institutions

21 Feb 2018

Banking groups urge EU regulatory forbearance powers for financial supervisors

23 Jan 2018
Feedback on — Review of European Supervisory Authorities' powers, governance and funding arrangements.
Their ask — The associations advocate amendments to empower ESAs with limited regulatory forbearance powers to defer legislative requirements in exceptional circumstances. They want ESAs able to direct national authorities not to enforce Union law when compliance is impossible, creates conflicts, or threatens financial stability. They also seek faster procedures for amending primary and secondary legislation.12
How it helps them — This would protect banks from enforcement when complying with EU rules is impossible or conflicts with other requirements.34
Who loses — Consumer and investor protections would be weakened when supervisors defer enforcement of financial rules.
Response to: Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL Amending Regulation (EU) No 1093/2010 establishing a European Supervisory Authority (European Banking Authority); Regulation (EU) No 1094/2010 establishing a European Supervisory Authority (European Insurance and Occupational Pensions Authority); Regulation (EU) No 1095/2010 establishing a European Supervisory Authority (European Securities and Markets Authority); Regulation (EU) No 345/2013 on European venture capital funds; Regulation (EU) No 346/2013 on European social entrepreneurship funds; Regulation (EU) No 600/2014 on markets in financial instruments; Regulation (EU) 2015/760 on European long-term investment funds; Regulation (EU) 2016/1011 on indices used as benchmarks in financial instruments and financial contracts or to measure the performance of investment funds; and Regulation (EU) 2017/1129 on the prospectus to be published when securities are offered to the public or admitted to trading on a regulated market

European Banking Federation opposes EU-wide NPL provisioning rules

7 Dec 2017
Feedback on — EU proposal for mandatory prudential backstops to prevent under-provisioning of non-performing loans.
Their ask — The EBF argues NPL problems vary by country and should be addressed at Member State level. They oppose additional EU legislation, calling it disproportionate since it tackles symptoms rather than root causes like inefficient legal proceedings. They want a full impact assessment before any decision.123
How it helps them — Banks avoid higher provisioning costs that would increase lending costs and restrict credit access.45
Who loses — Financial stability weakens as banks in high-NPL countries maintain insufficient loan loss buffers.6
Response to: Regulation amending Regulation (EU) No 575/2013 as regards prudential backstops preventing under-provisioning of non-performing exposures

European Banking Federation Seeks Voluntary Cybersecurity Framework

6 Dec 2017
Feedback on — EU proposal establishing ENISA's permanent mandate and ICT cybersecurity certification framework.
Their ask — The federation requests that certification schemes acknowledge existing financial sector standards and remain voluntary. They want formal industry participation in creating certification schemes, including representation in the European Cybersecurity Certification Group. They emphasize creating cost-effective and time-effective certification processes.123
How it helps them — This would help banks avoid duplicating their existing €53 billion IT investments and certification efforts.45
Response to: Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on ENISA, the "EU Cybersecurity Agency", and repealing Regulation (EU) 526/2013, and on Information and Communication Technology cybersecurity certification (''Cybersecurity Act'')

Meeting with Inge Bernaerts (Cabinet of Commissioner Marianne Thyssen), Piet van Nuffel (Cabinet of Commissioner Marianne Thyssen) and

27 Sept 2017 · Revision of the Written Statement Directive

European Banking Federation opposes delays to creditor enforcement rights

4 Aug 2017
Feedback on — EU proposal to protect secured creditors from business borrower defaults.
Their ask — The federation urges amendments to separate proposed restructuring frameworks from accelerated loan security. They warn that allowing debtors to delay creditor enforcement for up to 12 months will increase non-performing loans and contradict EU efforts to reduce them.123
How it helps them — This would protect banks from increased non-performing loans and maintain their capital ratios.45
Who loses — Struggling businesses lose breathing room to restructure debts and avoid bankruptcy.6
Response to: Accelerated Loan security - Protection of secured creditors from business borrowers' default

Meeting with Kai Wynands (Cabinet of Vice-President Valdis Dombrovskis), Raquel Lucas (Cabinet of Vice-President Valdis Dombrovskis) and

27 Jun 2017 · Role of Social partners in the Services Sector

Meeting with Inge Bernaerts (Cabinet of Commissioner Marianne Thyssen) and

27 Jun 2017 · Changing world of work, social dialogue

Meeting with Andrus Ansip (Vice-President) and

24 May 2017 · GDPR Implementation and Privacy Shield

Meeting with Valdis Dombrovskis (Vice-President) and

12 May 2017 · High Level Principles of SME credit feedback

Meeting with Valdis Dombrovskis (Vice-President) and

10 Apr 2017 · Euribor reform

Meeting with Elina Melngaile (Cabinet of Vice-President Valdis Dombrovskis)

4 Jan 2017 · PSD2

Meeting with Andrus Ansip (Vice-President) and

19 Dec 2016 · Discussion with industry on general data protection regulation implementation

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

15 Dec 2016 · Financial services agenda

Meeting with Valdis Dombrovskis (Vice-President) and

29 Sept 2016 · Basel framework; TLAC/MREL; Banking structural reform; CMU in the light of Brexit

Meeting with Renate Nikolay (Cabinet of Commissioner Věra Jourová)

19 Jul 2016 · CMU - Insolvency Law

Meeting with Jonathan Hill (Commissioner)

4 Apr 2016 · Financial Policy

Meeting with Andrus Ansip (Vice-President) and

15 Mar 2016 · DSM and digital banking

Meeting with Bernardus Smulders (Cabinet of First Vice-President Frans Timmermans) and

14 Jan 2016 · AECA Round-Table on “Dealing with Regulatory Burden

Meeting with Michelle Sutton (Cabinet of First Vice-President Frans Timmermans)

8 Dec 2015 · Financial services and better regulation

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

27 Nov 2015 · Speech "One year on – stock-taking and next steps for Financial Services" at EBF Financial Fridays Conference

Meeting with Matthew Baldwin (Cabinet of Commissioner Jonathan Hill)

18 Sept 2015 · Financial Policy

Meeting with Jasmin Battista (Cabinet of Vice-President Andrus Ansip), Laure Chapuis-Kombos (Cabinet of Vice-President Andrus Ansip)

2 Sept 2015 · Meeting on DSM in the banking sector

Meeting with Lee Foulger (Cabinet of Vice-President Valdis Dombrovskis)

6 Jul 2015 · Capital Markets Union/Prospectus Directive

Meeting with Denzil Davidson (Cabinet of Commissioner Jonathan Hill)

23 Jun 2015 · Financial Services Policy

Meeting with Jonathan Hill (Commissioner)

11 Jun 2015 · Banking regulation and capital markets union

Meeting with Valdis Dombrovskis (Vice-President) and

2 Jun 2015 · Banking regulation and sectoral social dialogue

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

4 Mar 2015 · EU fiscal policy

Meeting with Jon Nyman (Cabinet of Vice-President Cecilia Malmström), Maria Asenius (Cabinet of Vice-President Cecilia Malmström)

11 Feb 2015 · Financial services - Capital markets

Meeting with Nathalie De Basaldua Lemarchand (Cabinet of Commissioner Jonathan Hill)

22 Jan 2015 · Securitisation

Meeting with Jonathan Hill (Commissioner)

9 Dec 2014 · Financial services: priorities for 2015 including Capital Markets Union