European Structured Investment Products Association
EUSIPA
EUSIPA is the first and only pan European organization created to promote the interests of the structured investment products market which has grown strongly throughout Europe over the past years despite recent setbacks.
ID: 37488345650-13
Lobbying Activity
Response to Recommendation on savings and investment accounts
8 Jul 2025
EUSIPA understands that currently public funding needs (defence, infrastructure, pension system funding) and a related capital market engagement of retail investors is being pursued via two initiatives: the proposed Savings and Investment Account (SIA) and the recently unveiled Finance Europe label supported by seven countries, including France, Germany and Luxembourg and The Netherlands. While both aim to deepen the Unions retail capital markets and foster financial inclusion, their primary policy goals need clarification in our eyes. The SIA seems designed to support individual investors in building long-term personal financial resilience, especially for retirement. The Finance Europe label seems structured with a focus to serve the EUs strategic priorities by channelling retail savings into EEA-linked investment assets. These two instruments can be mutually reinforcing, on condition that: The design of any savings products and their distribution is being provided by the private banking/insurance sector only without being over-regulated and, with regard to the product design, without being artificially standardized as was tried in the past with the Pan-European Pension Product (PEPP) that failed to gain any market traction. The eligibility rules for products under both frameworks are coherent and product-neutral, ensuring that, for example, structured investment products (SIPs) are not arbitrarily excluded. A flexible and interoperable design is adopted, allowing SIAs to carry the Finance Europe label when appropriate, rather than forcing investors to choose between separate vehicles. Tax incentives under both schemes are coordinated to encourage both long-term saving and targeted capital allocation. EUSIPA wishes to underline again that Structured Investment Products, when properly regulated and transparently marketed, can bridge both aims - they offer tailored risk-return profiles for individuals saving for retirement, and they can certainly be designed to channel capital into companies headquartered within the EEA, thus aligning with the Finance Europe criteria. Key Message Structured investment products already represent a well-regulated and widely used investment class in many European countries. EUSIPAs recent internal survey of tax-privileged investment schemes in 12 countries (10 EU member states as well as the UK and Switzerland) found that in seven of the nine markets that maintain such tax-privileged investment schemes, SIPs are eligible assets, either directly or when held within insurance wrappers (these seven countries are Austria, Belgium, Czechia, France, Poland, Sweden and the UK). The before being said, many structured products are also aligned with the Finance Europe framework. Firstly, structured products would, with their bond component contribute to the funding of the European financial institution. Secondly, they are also commonly linked in terms of their underlying to EU national and pan-European indexes, baskets of shares or bonds from EEA-based issuers, making them easily meet the labels minimum 70% EEA content rule. In addition, their medium- to long-term nature means they are also well suited to the five-year holding periods promoted under the label but also considered for the SIA when it comes to minimum holding periods (in order to access, for example tax benefits). Aiming to avoid inconsistencies in practice, EUSIPA would recommend clarifying the connection and mutual goals of the SIA and Finance Europe frameworks. Concretely, EUSIPA proposes that SIAs be structured as versatile, multi-purpose accounts, with an optional overlay: once the accounts portfolio meets the Finance Europe labels criteria - such as the 70% EEA exposure and a minimum holding period - the investor could access additional benefits or branding associated with the label. This approach avoids duplication and helps reconcile investor-centric and policy-centric goals within a single framework.
Read full responseResponse to Revision of EU rules on sustainable finance disclosure
28 May 2025
EUSIPA strongly supports the regulatory landscape in the area of sustainable finance undergoing a recalibration and simplification effort. This effort ultimately should resolve the current absence of a substantive alignment between the SFDR rules and others, equally important regulatory frameworks such as MIFID and IDD, as well as important further cornerstones of product information disclosure such as the EU PRIIPs Regulation. Consequently, EUSIPA focusses its contribution to this Call for Evidence on the before aspect, taking this as an opportunity to reiterate core of our sectors positioning on the SFDR review, namely, to include structured investment products (also called "certificates" or "structured notes") into the scope of the SFDR. As in previous contributions to the SFDR review debate, EUSIPA takes the view that a major deficiency of the current rules is rooted in the fact that the SFDR leaves some major product formats/asset types completely unregulated, following its restricted product scope. This situation results not only in legal uncertainty at the business and consumer end but also triggers inconsistencies with regard to the offering of ESG products at the point of sale, finally creating, without any need, an unlevel playing field of products with ESG enhancing qualities. The major issue arising in this context is that for financial instruments MIFID obliges the distributor to inquire sustainability preferences of any investor asking for advice on ESG products, defined as the precise (%-wise) level of his/her minimum investment preference (with regard to the taxonomy and SFDR alignment) and, in qualitative regard, of the PAI consideration of the offered asset. This obligation obviously includes structured investment products with their ESG enhancing qualities, as these products are covered by MIFID (and IDD, should they be sold as insurance-based solution). Since MiFID requires to assess structured products sustainability features to match sustainability preferences of end-investors defined in relation to SFDR, EUSIPA and its member associations strongly advocate for structured products to be included within the SFDR scope. Doing so would also, to stress the obvious, follow the recommendation of both the Draghi and Letta reports on the EU capital markets in terms of their joint plea for a level-playing field in financial products offered to retail investors within the EU. Otherwise, the situation in practice continues to pose a huge challenge for all market participants dealing with structured products despite these asset class sharing, when designed with sustainability features, many similarities with SFDR covered products such as UCITS or IBIPs, e.g. when it comes to product governance obligations, the inclusion in ESG-labelled offerings and more generally, the ESG calibration of investor portfolios. In practice, the resulting legal uncertainty led to a best effort of the industry to adequately provide SFDR information, in an analogous way, also to structured investment products. This makeshift solution, however, often triggers intense discussions with regulators, additional verification between issuers and distributors and leads to an extra communication effort with investors. We also note that at the end of investor-directed disclosure, discussions took place to use PRIIPs KIDs for properly disclosing to retail investors sustainability features of investment products. It seems to us worthwhile hinting again at the fact that structured products, like UCITS and IBIPs are already included in the PRIIPs scope and would have been covered by any ESG information requirement under PRIIPs, in case such had been inserted. The absence of their inclusion in the SFDR scope would in that situation have created another inconsistency. EUSIPA hence would reiterate its position on the SFDR scope aspect, pleading clearly for an inclusion of structured investment products into the scope of a recast future SFDR.
Read full responseResponse to Savings and Investments Union
7 Mar 2025
EXECUTIVE SUMMARY EUSIPA Comment 1 - More flexibility at the retail point-of-sale | principles instead of details The value of many interactions between financial services and investors would substantially profit from establishing, going forward, framework rules with principles allowing for a certain flexibility rather than continuing to pass overly detailed and highly prescriptive micro-regulation that increasingly deters retail investors from engaging on the capital markets. National gold-plating in the EU currently often prevents efficient distribution of investment products to retail customers. A good example of the past where, except for the taxonomy itself, framework rules would have been advisable, is the distribution of ESG financial products to retail investors. An area where, going forward, one-sided (meaning risk-biased), overly detailed and prescriptive rules are to be avoided (e.g. by smart framework rules), is the judgement of product features on their Value-for-Money especially insofar as any such judgement refers to an assumed complexity/simplicity of product features. EUSIPA Comment 2 - Taxation relief is a as core investment driver. Tax-privileged investment schemes for retail customers must be held open to all asset classes for avoiding market distortions. As part of EU law-making, the massive impact of national taxation (relief) on retail investment behaviour must be better evaluated and considered in relevant legal acts. The, often detrimental, side impacts of national tax relief on cross-border investment flows must not result in an endeavour to force such investment flow, as wishful as it may be in theory from the EU perspective, through excessive regulatory advances in other areas, such as cost-only focussed Value-for-Money rules, excessive disclosure of information, wide-ranging advisory obligations and others, none of which bring noteworthy benefits to investors in practice or lead to cross-border investments. EUSIPA Comment 3 - Structured investment products have key features that make them highly suited for tax- or otherwise privileged long-term investment and savings schemes. Key arguments for considering structured products as eligible assets for tax- or otherwise privileged long-term investment (and/or pension savings) schemes are that: Structured products are mitigating risk as their yield expectation typically takes the space between a full exposure on the one hand, as direct investments in stocks or delta 1 instruments (ETFs) and fully capital-protected instruments such as cash holdings, on the other. This mitigation or in between function is why they exist. Structured products always deliver a clearly predictable yield under a certain (predefined) market scenario. They can be easily set up and tailored to all market expectations and risk levels. Many structured products allow to forecast a certain minimum return level as they have a fixed monthly/annual payout (coupon) and a full or partial capital protection. Structured products are responsive to taxation law requirements. Finally, Structured Products are also important in terms of cost considerations. In particular the absence of %-wise charged ongoing management fees make Structured Products especially attractive in the cost management of an investment portfolio.
Read full responseMeeting with Mairead McGuinness (Commissioner) and
18 Jul 2023 · Distribution of Retail financial products
Response to Quick fix to the PRIIPs Regulation
9 Sept 2021
EUSIPA, the European Structured Investment Products Association, makes reference to the attached joint statement issued together with a number of major financial sector associations.
Read full responseMeeting with Denzil Davidson (Cabinet of Commissioner Jonathan Hill)
15 Oct 2015 · Financial Services Policy
Meeting with Lee Foulger (Cabinet of Vice-President Valdis Dombrovskis)
17 Mar 2015 · Overview of structured products issues