EUROPEAN FINANCIAL PLANNING ASSOCIATION

EFPA

The mission of the European Financial Planning Association is to set, promote and implement high quality standards for competence and ethical behavior for the financial advisory sector throughout Europe, benefiting the profession, financial firms and clients.

Lobbying Activity

Response to EU taxonomy - Review of the environmental delegated act

4 Dec 2025

EFPA is the leading professional standards body for financial advisors and planners in Europe, with more than 100,000 certificate holders across 13 countries, including over 10,000 ESG Adviser certificate holders. EFPA responds to this consultation in that capacity. We welcome the opportunity to contribute to this important and timecritical consultation. From a financial advisory perspective, the scientifically informed technical screening criteria are extremely positive: They combat greenwashing and mitigate misleading claims./ They guide capital flows toward climateneutral, sustainable projects and enable access to funding at competitive rates./ They increase transparency by creating a common reference point for sustainable activity, setting a benchmark and enabling investment scaling across the EU. / They improve the EUs attractiveness for nonEU capital and firms, given global policy uncertainty./ We also note concerns: (1) The taxonomys technical criteria are complex and could be simplified to improve usability and support transition to a climateneutral, circular economy. (2) Compliance costs are high due to onerous reporting requirements and should be reduced. (3) Not all sectors are included (e.g. agriculture), limiting access to green funding. (4) Frequent changes to Delegated Acts may create uncertainty and delay investment. Additional observations: (5) Complex criteria delay sectoral coverage. A faster approach could use simplified criteria (e.g. agriculture) for a defined period to speed access to capital. (6) Simplification, while scientifically informed, would aid understanding by manufacturers, entrepreneurs, employees, analysts, advisors, and the public, generating higher adhesion. (7) Current scope limited to large companies may reduce investment in smaller firms, less able to prove green credentials. A simplified burden could help, e.g. streamlined do no significant harm principle, proportionate rules, or transitional/enabling activities. (8) Widening and deepening investment opportunities links to capital markets union: a single market would direct larger pools of capital to emergent green projects. (9) In drafting amendments to the Delegated Acts there may be an opportunity to enhance the communications strategy in relation to the taxonomy to reinforce political, corporate and investor alignment and understanding. This may help to reduce subsequent misunderstandings and minimise potential legal challenges (such as in the recent European Court ruling whereby nuclear and fossil gas could be included in the EU taxonomy). We make our comments in the spirit of trying to walk the tightrope between regulatory simplification to widen the breadth and depth of sectoral and firm size inclusion versus an idealised preservation of robust climate and environmental action at this critical juncture in the Green agenda. Reducing the regulatory burden in this domain was specifically mentioned in the Draghi Report as a mechanism to enhance competitiveness and innovation within the EU.
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Response to Recommendation on savings and investment accounts

8 Jul 2025

EFPA (European Financial Planning Association) appreciates the European Commissions efforts to support citizens across the EU in building financial resilience through simple and accessible saving and investment solutions. This initiative represents a promising path to better channel household savings toward long-term, productive investment. To realise this potential, several elements must be carefully considered: (1)Financial Education and Advisory Support A successful rollout hinges on a broad, pan-European campaign to improve financial literacy. Such a campaign should: (i) Differentiate clearly between saving and investing; (ii)Explain how returns relate to risk and investment duration; (iii)Help citizens grasp the trade-offs and risks, particularly for shorter holding periods. (2) Qualifications of Financial Advisors Financial advisors play a vital role in improving financial awareness and encouraging sound planning. We recommend introducing enhanced qualification requirements for advisors involved in promoting saving and investment accounts, in order to foster trust and consistency across Member States. (3) Product Design These accounts should constitute a distinct product category, separate from traditional savings or investment products. (i) Simplicity, transparency, and ease of access must be core attributes. (ii) Tax advantages. (iii)Appropriate holding periods to reinforce long-term behaviour. (4) Inclusivity To cater to different investor profiles, different tiers could be adopted: (i)A Basic Account, built around low-risk or capital-guaranteed instruments; (ii)An Advanced Account, permitting exposure to higher-risk investments, subject to a streamlined but effective suitability assessment. (iii)Others, if appropriate. This structure would broaden participation without compromising investor protection. (5) Time Horizon, Risk, and Return Saving and investment accounts should be designed with a minimum time horizon ideally five years or more to reflect the nature of capital markets. A gradual increase in risk exposure over time could help align performance expectations with actual market outcomes, reinforcing long-term engagement and financial discipline. (6) Cost Considerations and Governance Costs should be reduced only as long as this does not compromise quality. (i)Emphasis on diversification, sustainability, and investor outcomes. (ii)Strong governance and full transparency are non-negotiable in ensuring public confidence. (7) Portability and Open Access We fully support the vision of an open and portable saving and investment account ecosystem. Portability across providers should be guaranteed. ( 8) Fiscal Impact and Implementation Strategy (i) Any model must balance investor incentives with Member States fiscal realities. (ii)Rewarding savings based on real economic value creation, rather than nominal returns alone, may offer a pragmatic compromise. (9)A phased implementation starting with modest thresholds and scaling up over time may help secure national buy-in while maintaining alignment with broader EU fiscal goals.
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Response to Savings and Investments Union: Directive fostering EU market integration and efficient supervision

5 Jun 2025

The European Financial Planning Association (EFPA) is a standards-setting and qualifications-accrediting body operating within the European financial services sector. Established to serve the interests of both professional financial advisors and their clients, EFPA aims to raise public awareness of its members' activities and ensure their adherence to the professions ethical and regulatory standards. EFPA, in line with the objectives of the European Commission, strongly supports the consolidation of financial market infrastructures, the simplification of regulations applicable to financial services and the strengthening of European Financial Authorities in particular ESMA in the context of the Savings and Investments Union (SIU). The consolidation of infrastructure contributes to more efficient service delivery and smoother execution of client orders, fostering confidence among retail investors and strengthening the foundations for higher quality financial advice. EFPA considers it essential that the reduction of certain transparency requirements and the opening of the retail market to a wider range of products be accompanied by a strong push for qualified advice. Financial advisors play a key role in assessing the customer's profile and needs, including their sustainability preferences, and in recommending the most appropriate products. To do so, it is essential that they have the necessary knowledge and skills and continually update their competences. In this regard, EFPA calls on the European Commission to harmonise and consolidate the professional qualification requirements for financial advisors across the Union, covering the areas of investment, insurance and credit. This harmonisation should also include updated content on crypto-assets and artificial intelligence. We also propose the creation of a European label for professional certificates to identify advisors who meet the highest standards, thus facilitating their recognition by investors and raising trust to financial markets. EFPA strongly supports the facilitation of cross-border distribution of investment funds, which would enable advisors to offer their clients a wider and more appropriate choice of products. On the other hand, regulatory simplification particularly by limiting the excessive development of Level 2 rules (RTS) would ease the regulatory burden and enable a more efficient and understandable relationship between advisors and clients. Clearer rules are not only easier to apply but also contribute to more effective supervision. This simplification process should include more precise and accessible guidelines on suitability assessment for both advisors and clients. Regulatory simplification must go hand in hand with a co-regulation strategy, especially in increasingly digitalised markets and products influenced by artificial intelligence. In this environment, the active involvement of financial intermediaries, including advisors, and the professional associations that represent them is essential. EFPA is ready to actively contribute to this process, bringing its expertise in self-regulation to facilitate regulatory compliance. Finally, EFPA reiterates its willingness to collaborate with the European Commission in the design and implementation of the Savings and Investments Union. The accumulated experience of financial advisors, exceeding today 100 000 EFPA certificate holders always focused on client interest and protection, can provide valuable insight into the construction of a regulatory framework that ensures a competitive, efficient and truly investor-oriented market that channels savings into productive investments.
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Meeting with Sirpa Pietikäinen (Member of the European Parliament)

3 Jun 2025 · Financial literacy and education

Response to Savings and Investments Union

5 Mar 2025

The European Financial Planning Association (EFPA), representing over 100,000 certified financial professionals across Europe, supports the European Commissions initiative for the Savings and Investment Union (SIU), which aims to improve the efficiency of capital markets, mobilize private savings, and enhance investment opportunities throughout the EU. EFPA strongly believes that the success of the SIU hinges on the integration of professional standards, financial education, and investor protection. EFPA recognizes that the SIU must prioritize the professionalization of financial advisors. It is critical to establish harmonized certification standards across the EU to ensure that financial advisors provide ethical, transparent, and high-quality advice. This would empower investors to make informed financial decisions, which is essential for building trust in capital markets. Moreover, a focus on improving financial literacy and investor education across Europe is key to the SIUs success. EFPA advocates for EU-wide financial education initiatives that are practical, regularly updated, and tailored to different social and age groups, which would help citizens make better financial and investment choices. EFPA also stresses the importance of providing retail investors with accessible, cost-effective, transparent, and easy-to-understand investment products. This is crucial in the context of long-term savings and retirement planning. EFPA also advocates for greater harmonization of regulations across EU member states, as the current fragmentation remains a barrier to cross-border investment, and harmonizing tax rules and administrative procedures would streamline investment processes and enhance the overall investment environment. While innovation, particularly in fintech and digital finance, presents new opportunities, EFPA underscores the need to balance progress with strong investor protection. Safeguards must be in place to prevent risks such as misinformation, fraud, and the sale of overly complex financial products. However, these protections should not stifle the development of new financial tools that could benefit investors. Furthermore, EFPA supports the growth of private equity and venture capital as essential drivers of innovation. These funding sources are key for supporting startups and emerging industries, particularly in sectors like AI and sustainable technologies. To foster growth in these areas, it is important to create a regulatory environment that attracts private investment, reduces administrative barriers, and supports long-term investment in high-potential businesses. In its response, EFPA proposes the creation of a pan-European label for financial advisors, which would facilitate cross-border advisory services and help build trust in financial qualifications. This label should incorporate clear standards for professional ethics, continuous professional development, and measurable learning outcomes. Additionally, EFPA advocates for reducing regulatory and tax barriers to make compliance easier, which would encourage investment while maintaining investor protection. EFPA believes that the financial services sectors harmonization can lead to greater scale, integration, and competitiveness within the EU. Drawing from its experience in standardizing financial advice, EFPA demonstrates that increased harmonization is possible and beneficial. EFPA remains committed to contributing to the development of the SIU and looks forward to engaging further with policymakers to shape a framework that strengthens Europes financial markets, prioritizing consumer protection and access to professional advice. Please find attached the short document presenting our position extensively, including detailed feedback and recommendations on how to enhance the proposed framework. We look forward to ongoing dialogue with the European Commission to help shape a robust and inclusive financial ecosystem for all EU citizens.
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Meeting with Philippe Thill (Cabinet of Commissioner Maria Luís Albuquerque)

26 Feb 2025 · Exchange with the European Financial Planning Association (EFPA) on financial literacy, financial advice and retail investment

Meeting with Markus Ferber (Member of the European Parliament)

3 Dec 2024 · Retail Investment Strategy

Response to Retail Investment Package

23 Aug 2023

As a leading professional body for financial advisors and planners in EU, gathering a community of over 90 000 professional certificate holders, at EFPA we believe that today it is one of our key goals and motivations to make skills matter in the process of implementing the new RIS. We are convinced that more harmonisation and quality is not only possible but also needed for qualifications of financial advisors in Europe if RIS is to deliver on its goal of empowering and protecting retail investors in EU, making them comfortable and eager to use financial products to reach their life goals, and providing for secure retirement. We are sending the message that we can improve financial advice for clients in EU under RIS through better qualifications of financial advisors. Qualifications which are transparent, reliable and updated focused around the client and not around the products, and are binding across leading regulatory regimes, including MiFID, PRIIPS and IDD. We subscribe to the statement that what is measured, gets improved (Peter Drucker). We argue that we need common language, common measurements and better common standards for professional qualifications of financial advisors in EU, to support the implementation of RIS objectives. The good news is that substantial work and progress has already been done. We can build on what we have. With moderate effort much advancement can be achieved. We at EFPA have analysed the current regulatory requirements under MiFID II and IDD and propose to bring the CMU idea of a pan-EU label for financial advisors to life across the regulatory regimes though a transparent harmonisation process. To do that we recommend using the existing solutions, unifying and upgrading them. We propose that the following key features constitute the new pan-EU label for qualifications of financial advisors: 1. Professional financial advisors in EU hold a qualification. 2. A qualification is a formal outcome (certificate, diploma or title) of an assessment and validation process which is obtained when a competent body determines that an individual has achieved learning outcomes to given standards and/or possesses the necessary competence to do a job in a specific area of work. A qualification confers official recognition of the value of learning outcomes in the labour market and in education and training. 3. A qualification should be described with learning outcomes (knowledge, skills, competences), should have a measure of the level of complexity (EQF levels is a good benchmark tool) and should provide clear validation rules to confirm that the learning outcomes contained in the qualification have been achieved. There are different client segments that are serviced by financial advisors in a variety of their professional roles. We need different qualifications to support the different roles. 4. The qualification should contain professional ethics standards requirements. 5. The qualification should have a continuous professional development requirement, specifying the volume of effort required, the reporting format and the time frame to meet the requirement. With this approach we shall build a system of transparent, reliable and meaningful qualifications of financial advisors in EU, serving a variety of clients and their needs. Financial advisors should exhibit appropriate levels of professionalism adequate to their roles, building trust, security and engagement in their relationship with clients. Financial advisors need recognition of their work craft to stand up to the challenge of educating clients, guiding clients through the ever growing complexity of financial markets, helping them to identify and fulfil their key financial goals with investment products. Lets make the skills of financial advisors matter in the implementation of the RIS for the financial well-being of clients and the growth of the financial market in the EU. Please, refer to our position paper and presentation in attachment.
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Meeting with Mairead McGuinness (Commissioner) and

18 Jul 2023 · Distribution of Retail financial products