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Febelfin

Febelfin is de overkoepelende federatie voor de Belgische financiële sector en zij vertegenwoordigt ongeveer 250 financiële instellingen in België.

Lobbying Activity

Meeting with Andrea Beltramello (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

12 Dec 2025 · Savings and Investments Union (SIU), Market Integration Package (MIP)

Meeting with Johan Van Overtveldt (Member of the European Parliament)

18 Nov 2025 · International Financial and Geopolitical Context

Response to Digital Fairness Act

24 Oct 2025

Please find our full feedback and annex with concrete examples attached. Febelfin welcomes the opportunity to contribute to this consultation and appreciate the Commissions continued efforts over recent years to shape a European digital framework. However, regarding the DFA, we believe that the current priority should be to assess and reflect on a coherent application of existing rules and, as the case might be, adapt existing legislation where necessary. In our view, the DFA would not fill a gap but rather increase complexity by adding new concepts or definitions, redefining existing practices, creating conflicting obligations. Giving the current legal framework, we believe, the core problem is not a lack of regulation, but rather the need of clarifications and a coherent and well-articulated interplay between existing texts. While this may require a different kind of effort, it is essential for the Commission to remain consistent with its stated objectives around simplification. This process should also take into account sector-specific frameworks, including the possibility of exemptions for the financial sector, where tailored regulations already apply. Ultimately, such an approach will better serve consumers by ensuring more effective and consistent protections across the digital landscape.
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Meeting with Nicolo Brignoli (Cabinet of Commissioner Valdis Dombrovskis)

14 Oct 2025 · Digital euro

Meeting with Lauro Panella (Cabinet of Commissioner Maria Luís Albuquerque), Nuno Vaz (Cabinet of Commissioner Maria Luís Albuquerque), Philippe Thill (Cabinet of Commissioner Maria Luís Albuquerque) and Assuralia, beroepsvereniging van verzekeringsondernemingen

15 May 2025 · Thematic roundtable with Febelfin and Assuralia on the Savings and Investment Union

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

30 Apr 2025 · AI in Financial Services

Response to Savings and Investments Union

7 Mar 2025

Please find our submission attached. Febelfin, the Belgian Financial Sector Federation, represents the majority of the Belgian financial sector, including banks, credit providers, asset and fund managers, market infrastructures, stockbroking firms and stockbrokers, leasing companies, etc. Our broad representation basis delivers a comprehensive and balanced position that considers the unique characteristics of various branches within the financial industry.
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Meeting with Kathleen Van Brempt (Member of the European Parliament) and AGORIA and

21 Jan 2025 · Rondetafel industrieel beleid, clean industrial deal en blik op komende wetgeving

Meeting with Wouter Beke (Member of the European Parliament)

2 Oct 2024 · Capital Markets Union

Response to Open finance framework

31 Oct 2023

Please find enclosed, the response of Febelfin, the Federation of the Belgian Financial Sector, to the proposal for a Framework for Financial Data Access (FIDA).
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Response to Payment services – revision of EU rules (new Regulation)

31 Oct 2023

Febelfin, the Federation of the Belgian Financial Sector, has assessed the Commissions proposal for a Payment Services Regulation in detail and welcomes some necessary updates that can ensure that the legislative framework reflects the current state of the payments market, provided that some important elements are integrated, most notably on fraud (prevention) and liability and open banking. However the Belgian industry has various comments from both a legal and operational standpoint. Please find attached, our response to the Have your Say consultation, we wish to emphasize our primary concerns.
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Meeting with Johan Van Overtveldt (Member of the European Parliament)

20 Oct 2023 · Economic and monetary policies

Response to Retail Investment Package

28 Aug 2023

Please find our response in the document attached.
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Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur) and BUSINESSEUROPE and

8 Mar 2023 · Corporate Sustainability Due Diligence

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis) and Banco Santander, S.A. and

1 Feb 2023 · retail investment strategy

Meeting with Agnieszka Drzewoska (Cabinet of Commissioner Mairead Mcguinness) and Banco Santander, S.A. and

1 Feb 2023 · Retail Investment Strategy

Meeting with Kathleen Van Brempt (Member of the European Parliament) and VERBOND VAN BELGISCHE ONDERNEMINGEN / FEDERATION DES ENTREPRISES DE BELGIQUE and

17 Jan 2023 · Roundtable discussion - A stronger Europe in the World

Response to Instant Payments

4 Jan 2023

Febelfin welcome the proposal for legislating instant credit transfers (SCT Inst). SCT Inst are an important building block of the future EU payments market. Statistics show SCT Inst are already widely adopted and offered in Belgium. Today about half of Belgian institutions offering credit transfers, offer SCT Inst, these cover 96,5 % of all payment accounts in Belgium. Today, almost half of the total SCT volume done by individuals is processed instantly and this number is steadily increasing. Although we are supportive of EU-wide euro SCT Inst, the legislative proposal is too broad and not balanced enough. The current proposal would oblige all banks to offer SCT Inst to all their customers through all channels, which is disproportionate to the objective pursued and the needs of the market. Febelfin recommends to reduce the scope to not include niche banks or smaller credit institutions that are not necessarily active in the retail market or focus on investment advice. With regard to channel, legal requirements should be limited to one online channel. Also, offering SCT Inst for bulk payments is technically highly complex and even not feasible. It is very important to note that the obligations laid down in the proposal (for offering, receiving, IBAN name check) would imply huge investments and processing costs for use cases and PSU interfaces without added value and could imply higher fees for payment services in general. We believe that a specific pricing for SCT Inst is also justified because of the costs for offering are higher (development, risk mitigation, fraud prevention,). The EU payments market has thousands of competing PSPs and prices should always be left to be determined by market competition. When SCT Inst was implemented in Belgium, it was decided to leave the product offering up to each individual bank. This has led to a differentiated product offering with competitive pricing. Competition should be allowed to play its role and will anyway drive-out any pricing that does not correspond to the cost. A service with added value should be able to be priced accordingly. The proposal will contribute to further creating imbalances as it prohibits banks as market participants that are building the SCT Inst rails to recover the cost of their investment, while other market participants such as Third Party Providers (TPPs) will be able to enhance their service offering based on the SCT Inst infrastructure put in place by banks and charge for their services (usually merchants). The proposal also does not put in place elements of a business model or framework, that would be needed for payment solutions at PoS and e-commerce, similarly to the card business model. Building an IBAN name check at EU level would be a major project. According to us this should be developed according to a scheme-like approach to facilitate the pan-European interoperability. This takes time and resources, which should not be underestimated. There are numerous challenges to consider and solve. Once an EU scheme has been established, banks also need sufficient time to implement the solution in their own system. Belgian banks are busy working on a domestic scheme, in this context, the discussion about a possible EU scheme is highly relevant. The concrete details will therefore depend on the availability of such a scheme. We welcome the proposal to make the screening process for SCT Inst more efficient. Indeed, it has become increasingly evident that the current sanctions screening framework needs to be amended before SCT Inst can be scaled to the level of new normal. The main issue related to intra-EU cross-border SCT Inst (or domestic SCT Inst in some countries) is the fact that they create a high level of false positive alerts generated in transaction screening, causing rejects. A move from transaction-based screening to client database screening is therefore a welcome proposal. Detailed comments and recommendations can be found in annex.
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Response to Climate change mitigation and adaptation taxonomy

14 Dec 2020

The Belgian financial sector federation (Febelfin) and his constitutive member "Union Professionelle du Crédit" entirely support the feedback given by the European Mortgage Federation on the Taxonomy Delegated Act : 1. Acquisition & ownership of buildings The proposal that pre-2020 buildings must have at least EPC A (mitigation) to be taxonomy eligible would significantly impact market critical mass by reducing (up to 95%) eligible assets, with knock on effects for the entire value chain, from eligible mortgages to Taxonomy aligned green bonds. Indeed, 90% of the building stock was built before 2001 and EPCs vary across countries: for example, buildings with EPC A may only represent 1% of the building stock in some countries. Moreover, upgrading a low energy level building to EPC A is extremely difficult technically, economically and financially and will create ‘stranded assets’ in the housing market for consumers, lenders and investors. This will disincentivise banks and borrowers to favour better homes when purchasing and financing. Post COVID-19, the proposal will be socially exclusive for less affluent citizens in less efficient buildings. Finally, the proposal creates a ‘moral hazard’ by disincentivising Member States from tightening of EPC definitions and jeopardises a level-playing field. We strongly support a more inclusive approach where, in addition to EPC A (mitigation), buildings in the “top 15% of the local existing stock” will be considered taxonomy eligible. The EEM Label will support consumer demand and provide a gradual market alignment mechanism for banks, enabling them to demonstrate portfolio eligibility and deliver transparency and best practice at European and global level. 2. Renovation of buildings The renovation of the existing building stock is key to upgrade EPC levels and promote EPC alphabetisation. Only buildings sold or rented since 2010 have an EPC so many do not. The Renovation Wave will help drive the qualitative upgrade of bank portfolio energy profiles, enhance asset quality in terms of loan to value and improve borrower disposable income. This aids financial stability by reducing NPLs and making bank books more resilient. Green renovations boost employment, achieve positive socio-political impacts and fight energy poverty. It is therefore important that the entirety of renovation loans be ‘eligible transition activities’ when at least 50% relates to energy efficiency. When expenditure cannot be distinguished by type, 50% of the total renovation cost should be the proxy of energy efficiency. Furthermore, where costs cannot be practically separated in loans for acquisition and renovation, acquisition costs should be considered integral with eligible renovation costs. Finally, when determination of whether the loan relates to energy efficiency is not feasible, which is often the case for mortgages to retail customers, eligibility should be based on a minimum 30% decrease in primary energy demand certified by an EPC pre- and post-renovation. 3. Construction of new buildings The EPBD aims to achieve the Paris climate goals in the building sector and the NZEB definitions should be designed accordingly. Consequently, for new buildings it should be sufficient to refer to the NZEB standards. 4. DNSH Some of the DNSH requirements and the evidence required cannot be met by the financing institutions. EG, due to a lack of national regulations/laws and therefore of data collection, proof of water consumption is unavailable. First, legal requirements should be addressed to manufacturers, before a corresponding legal standard can be set up.
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