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European Forum of Securities Associations

EFSA

EFSA is a forum of European Securities Associations for information sharing and fostering mutual understanding.

Lobbying Activity

Meeting with Martin Merlin (Director Financial Stability, Financial Services and Capital Markets Union) and Association Française des Marchés Financiers

9 Dec 2025 · Conference: Improving the integration of EU capital markets for a more competitive Union

Meeting with Philippe Moseley (Cabinet of Commissioner Dan Jørgensen) and Fire Safe Europe

22 May 2025 · Housing, fire safety, sustainability

Meeting with Valentina Schaumburger (Cabinet of Executive Vice-President Stéphane Séjourné)

14 May 2025 · Enforcement of Single Market rules

Response to Retail Investment Package

28 Aug 2023

Key points (See full response in attachment): - EFSA wants to highlight that from a CMU-perspective it is important to always make the competitiveness and attractiveness of EU capital markets, including for EU market participants such as SMEs, a part of the impact analysis. This is in particular the case as the UK has announced that it intends to simplify its regulatory framework. - EFSA is not in favour of a total ban on inducements which in our opinion would lead to negative effects for many retail clients in the EU, by creating an advice gap and limiting the clients access to a broader product offering. - EFSA also has strong concerns in respect of a new partial ban on inducements for execution services and wants to underline that it is very important from a CMU perspective that retail clients can access the market through different types of services and products and that investment firms are able to compete with different business models. We also see substantial operational challenges with a partial ban for execution services which will negatively impact the provision of ongoing services to many retail clients at the same time as it provides very little benefit in terms of removing conflict of interest. - EFSA also finds the new best interest of client- test to be very complex and that the proposals give rise to many questions. We are especially concerned with the cost-focus of the best interest test which we fear will limit the product offering to the detriment of retail clients and we find it difficult to understand how this new test shall be aligned with the existing suitability regime and the rules on clients sustainability preferences. - EFSA is supportive of the principle that clients should get value for money but strongly objects to the introduction of centralized EU benchmarks. In our view, this proposal is equivalent to a price regulation at EU-level, and it also gives rise to serious concerns from an implementation perspective. We do not agree with the focus on low costs index products since also other aspects than costs are important from a retail client perspective, e.g., the risk of the product, diversification of the clients portfolio as a whole and also other factors such as sustainability preferences or tax regime. We are also worried that the development of EU benchmarks, that will have to be granular enough to allow meaningful comparisons, will be an extremely complex exercise for the ESAs, in particular considering the very wide scope of the proposed vfm-regime and the benchmarks could also give rise to liability concerns. - EFSA welcomes proposals that aim to simplify and tackle the existing problems with information overload to retail clients, including a review of the opt-up regime for sophisticated clients. However, we are concerned that some of the ECs proposals will have quite the opposite effect and could in fact increase the complexity to little benefit for clients, e.g., the extension of the suitability and appropriateness regime. - EFSA is concerned by the fact there has not been a thorough cost/benefit analysis nor consumer testing of all the proposals and notes that many details will be determined on level 2 which makes the impact of the proposals difficult to analyse (such as many of the new reporting requirements). - EFSA considers that the link between some of the proposals by the EC and the policy goal of increasing retail clients participation on the capital market is quite weak. It is therefore important that the co-legislators require that a study is carried out ex post in order to analyse whether the amendments made by EC to MiFID II, IDD and PRIIPs actually have had any effect on the policy objective.
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Meeting with Mairead McGuinness (Commissioner) and

18 Jul 2023 · Distribution of Retail financial products

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

14 Mar 2023 · Retail investment strategy

Meeting with Agnieszka Drzewoska (Cabinet of Commissioner Mairead Mcguinness)

14 Mar 2023 · Retail investment strategy