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Finance Sweden

Finance Sweden represents banks, mortgage companies and credit institutions in Sweden, advocating for their interests in regulatory matters.

Lobbying Activity

Meeting with Arba Kokalari (Member of the European Parliament) and Swedbank AB (publ) and

2 Dec 2025 · Financial Markets Regulation & Savings Investments Union

Meeting with Adnan Dibrani (Member of the European Parliament, Committee chair) and NASDAQ and

13 Nov 2025 · Savings and investment union

Meeting with Adnan Dibrani (Member of the European Parliament, Committee chair)

7 Nov 2025 · Digital euro

Meeting with René Repasi (Member of the European Parliament, Rapporteur) and Afore Consulting and Paysafe Ltd

24 Oct 2025 · Payment Services Proposals

Meeting with Arba Kokalari (Member of the European Parliament)

23 Oct 2025 · Savings and Investments Union

Finance Sweden warns Digital Fairness Act creates unnecessary complexity

22 Oct 2025
Topic — This consultation examines gaps in consumer protection against unfair practices in digital markets.
Message — Finance Sweden opposes new legislation as existing rules already forbid dark patterns and misleading marketing. They claim additional laws would create unnecessary complexity where rules already exist. The association believes current directives serve consumers well without needing further intervention.12
Why — This approach helps banks avoid new administrative burdens and protects risk-based pricing models.34
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Meeting with Damian Boeselager (Member of the European Parliament)

16 Oct 2025 · SIU

Meeting with Tomas Tobé (Member of the European Parliament) and Finanssiala ry - Finance Finland and

24 Sept 2025 · Finance Policy

Meeting with Katri Kulmuni (Member of the European Parliament) and Finanssiala ry - Finance Finland and

24 Sept 2025 · Nordic Finance evening -vastaanotto

Meeting with Antti Timonen (Cabinet of Executive Vice-President Henna Virkkunen), Marlene Rosemarie Madsen (Cabinet of Executive Vice-President Henna Virkkunen) and

24 Sept 2025 · Exchange about important digital policy priorities with representatives of Nordic Financial Associations

Meeting with Katri Kulmuni (Member of the European Parliament)

11 Sept 2025 · Parlamentti, EU-politiikka

Finance Sweden calls for simple, national-level retail investment accounts

7 Jul 2025
Topic — Creating a European blueprint for savings and investment accounts to boost retail participation.
Message — Finance Sweden supports a flexible EU blueprint for savings and investment accounts implemented nationally. They advocate for minimal restrictions, including broad asset eligibility and the removal of deposit limits. They recommend that the Commission focus on sharing best practices rather than creating new legislation.123
Why — Flexible national implementation avoids new compliance costs and protects existing successful Swedish investment products.45
Impact — Advocates for centralized EU financial products lose as the group opposes creating new retail sub-brands.67
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Meeting with Jörgen Warborn (Member of the European Parliament, Rapporteur)

16 May 2025 · Omnibus

Meeting with Maria Luís Albuquerque (Commissioner) and

2 Apr 2025 · Savings and Investments Union – exchange with Swedish institutional investors and intermediaries

Meeting with Jörgen Warborn (Member of the European Parliament, Rapporteur) and Confederation of Swedish Enterprise and EUROCHAMBRES – Association of European Chambers of Commerce and Industry

25 Mar 2025 · Omnibus

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

21 Mar 2025 · AI in Financial Services

Finance Sweden urges permanent lower stable funding factors

10 Mar 2025
Topic — A targeted amendment to EU banking rules regarding reverse repo treatment.
Message — Finance Sweden supports permanently maintaining lower Required Stable Funding factors for securities financing transactions. They urge the Commission to implement these changes before the June 2025 deadline.12
Why — This would prevent increased market friction and maintain the efficiency of covered bond markets.34
Impact — Households and investors face higher costs if the current favorable treatment is not maintained.5
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Response to Savings and Investments Union

6 Mar 2025

Crucial for well-functioning capital markets is a business climate focused on developing innovations and marketing them in a way that allows investors to receive a high return on investments. For creating a vibrant capital market, it is not enough to create rules and frameworks. Build on the experiences from existing well-functioning capital markets The EU and its member states should seek inspiration from EU countries that already have well-developed capital markets. Many of the factors that explain the functioning of capital markets are national competences, such as taxes and pension systems. Measures to promote EU capital markets should not harm already well-functioning national markets. Overall, marked-oriented solutions should be preferred focusing on measures that open up markets and promote competition. Action on the investment side is needed but should not overshadow the importance of creating better general business conditions, supporting growing companies. Reducing and simplifying disclosure regulations for listed companies and further reducing administrative burdens within the field of taxation should be considered. Work with indicators EU could further develop the CMU monitoring mechanism, agreeing on relevant KPIs to measure competitiveness and gather capital markets experts advising the COM, building on the current toolkit of indicators (i.e. Document Monitoring progress towards a Capital Markets Union: a toolkit of indicators SWD[2021] 544). Member states could be encouraged to develop national capital market strategies; inspiration could be drawn from the scoreboards, assessments and recommendations regarding public finances. No need for a European Investment and Savings Product There is no need for a regulated investment product beyond those that exist in some markets in particular ISA, and mutual funds for the broader retail market. The same flexible and market-driven approach could be used in other member states. Occupational auto-enrolment may be one important key to develop an investment culture in member states where that is missing. It should be promoted within EU by sharing of best practices. The experiences from the Pan-European Pension Product (PEPP) emphasizes the need to avoid misguided focus on regulation where there is no market failure. Investment restrictions of retail products focusing on European assets may greatly harm consumer confidence if returns turn out to be better elsewhere. An EU product/label/wrapper/account with geographical restrictions should therefore be avoided. ISAs The Swedish experience of an investment culture is based on mutual funds for the broader retail market, further advanced by an ISA (in Sweden: ISK). Solutions such as these can be used to simplify administration and give tax incentives to promote long-term investments with broad participation. Supervision Regulatory harmonisation and gradual supervisory convergence are generally preferred approaches. Differences in supervisory expectations and practices might harm the single market and create unlevel playing fields. This suggests that there are gains to be made with more regulatory convergence and underscores the need to avoid goldplating, but taking this to advocating for general centralised supervision is too far-reaching and premature. A significant part of securities legislation is still national, even in areas that are largely harmonised. This is the case, for example, within mutual fund law, where the UCITS directive and the AIFM directive have been implemented in national legislation with somewhat different features. NSAs are better suited to supervise applicable national legislation. Selfregulation of corporate governance and reporting is an important part of the of the Swedish financial markets. Increased supervisory convergence should not harm existing well-functioning supporting structures. Financial Market Infrastrastructure consolidation Consolidation should be market driven.
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Meeting with Emiliano Tornese (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

10 Feb 2025 · Macroprudential review for banks

Meeting with Alice Teodorescu Måwe (Member of the European Parliament)

7 Feb 2025 · Informative session

Meeting with Adnan Dibrani (Member of the European Parliament)

25 Sept 2024 · Introduktion till de nordiska finansiella förbunden

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

9 Apr 2024 · Priorities for next EU term; Future EU agenda in financial services.

Response to Payment services – revision of EU rules (new Regulation)

1 Nov 2023

Please find attached the views of the Swedish Bankers' Association on the proposal.
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Response to Establishing the digital euro

8 Sept 2023

Please see feedback attached, authored by the Swedish Bankers' Association
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Response to Instant Payments

4 Jan 2023

Please find attached the response from the Swedish Bankers' Association.
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Meeting with Arba Kokalari (Member of the European Parliament, Rapporteur)

19 Oct 2022 · Financial services contracts concluded at a distance

Response to Open finance framework

14 Jul 2022

Data protection and respecting the GDPR principles need to be the focus of any initiative in the data sharing area especially as data literacy amongst consumers is still at a low level. It’s vital to ensure that the customer understands which consents they approve and to whom and on a regular basis receive an update of said consents and how to manage these. These objectives are underpinned by the requirements for financial providers and any provider should adhere to the same regulatory frameworks and requirements. Further clarifications of the responsibilities of all PSPs especially concerning consents and the processing of data will ensure high levels of consumer protection. Assuring that fraud risks are kept to a minimum is furthermore crucial when developing an open finance framework. In line with GDPR and bank secrecy act, the control of access and processing of personal data always needs to lie with the service user who should instruct the data custodian who should have access. It is crucial that consumers understand that any transfer of data to providers outside the banking system removes the protection of customers’ data through bank confidentiality legislation which has traditionally been a cornerstone of trust in the European banking system. An open finance framework requires common clear rules, frameworks and aligned supervision by the national competent authorities across member states, on how data can be used to ensure that European citizens maintain full control and access to their data. It is also important that this development considers the level playing field regarding the regulatory agenda for all providers. The SBA agrees with the Commission that the existence of many different APIs, have presented challenges for the industry, especially for TPPs. The SBA welcomes finalisation of the private industry initiative on a SEPA Application Programming Interfaces Access Scheme. This will remove any discussions concerning obstacles to TPPs’ services without limiting future innovation. The finalisation of SEPA is an important step to create standardized and dynamic APIs both from a commercial, legal and technical perspective. In this regard API standards are important. An open banking framework should be technology neutral. Focus should be on regulating the activity and not the technology itself in order to foster future innovation and not risk of locking the industry into existing regulated technologies that could rapidly be outdated. To enable data sharing the service providers that will share customer data with third parties must invest in sufficient solutions. If there is a lack of commercialization there will be a gap in investment as there are not enough incentives. In any future policy, data management, commercialization and reciprocity need to be the main focus. In this respect the principles in the Data Act should be respected. As part of the Commission’s impact analysis cyber risks and operational resilience should be included. When opening up for customer data to be transferred outside the supervised intermediaries’ control, it will not only open up for new service opportunities but could also bring new operational risks. Supervised intermediaries cannot for example control to what third parties that data is shared, and what linkages these parties have to new custodians such as corporates/organisations. Consequently, a potential open Finance framework should focus on voluntary data sharing between regulated entities. Sharing of data beyond that could increase the risks for fraud, ID theft, privacy and data breaches, cyber and information security risks. Data-sharing beyond PSD2 should be pursued only on a cross sectoral level. Moving beyond the PSD2 framework towards open finance without also acting in other sectors could deepen the existing data asymmetry faced by banks and heighten the risks associated with it.
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Meeting with Othmar Karas (Member of the European Parliament, Shadow rapporteur) and Finanssiala ry - Finance Finland and Finance Denmark

18 May 2022 · Reform der EU-Bankenregulierung (CRR3/CRD6)

Meeting with Karolin Braunsberger-Reinhold (Member of the European Parliament, Shadow rapporteur) and Finanssiala ry - Finance Finland and

22 Apr 2022 · AMLR

Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

30 Mar 2022

The Swedish Bankers’ Association represents banks and financial institutions established in Sweden. Our aim is to contribute to a sound and efficient regulatory framework that facilitates for banks to help create economic wealth for customers and society. The banking industry's role in climate change is to support its customers in the transition to sustainable solutions and to integrate climate-related risks and opportunities into the banks’ operations and lending. Swedish banks generally support efforts to achieve energy efficiency and reduction of emissions from buildings and thus also support the goal of the EPBD revision. We stand ready to further contribute to the financing of this transition. The current proposal is, however, far-reaching, retroactive and raises societal issues that governments and decision makers must solve, not least regarding how to ensure that all buildings – and homeowners – should live up to the new requirements. Highlights • Swedish banks generally support efforts to achieve energy efficiency and reduction of emissions from buildings and stand ready to further contribute to the financing of this transition. • The proposal means that around 80% of buildings in Sweden will need renovations before 2050, by definition, 15% already before 2030, and then renovation needs continue in the same pace 2030-2050. • Ensuring that all homeowners can live up to the new requirements will be challenging and will strike at already vulnerable groups in society. • Renovations of some buildings are not cost-effective, thus posing risk that such buildings would lose their value and become stranded assets. This might result in negative spill-overs to the real estate collateral value and financial institutions. • Simple, cost-efficient certification process, harmonization of EPCs across the EU and data transparency are crucial to achieve the EPBD policy goals. For a complete response, please see uploaded file.
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Meeting with Luis Garicano (Member of the European Parliament, Rapporteur) and Finanssiala ry - Finance Finland and Finance Denmark

3 Mar 2022 · Meeting with stakeholders

Finance Sweden Warns Capital Rules May Hike Nordic Financing Costs

16 Feb 2022
Topic — The European Commission is aligning EU banking rules with international Basel III standards for capital requirements.
Message — The organization calls for a permanent and more risk-sensitive implementation of the output floor for loans. They argue that temporary adjustments for unrated companies and residential mortgages should be made permanent to reflect market structures.12
Why — This would prevent a sharp rise in capital requirements and maintain Nordic banks' competitiveness.34
Impact — Homeowners and businesses face higher costs and reduced access to bank lending for investments.56
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Finance Sweden opposes new mandatory pre-approval of bank executives

14 Feb 2022
Topic — Proposed amendments to the Capital Requirements Directive (CRD6) regarding banking supervision and risk.
Message — Finance Sweden rejects the shift to mandatory ex-ante suitability assessments for bank leaders, preferring the existing system of internal checks and ex-post regulatory reviews. They also request reduced complexity in supervisory benchmarking exercises and clearer rules for avoiding double-counted risk.123
Why — The organization avoids significant administrative delays and maintains its ability to fill critical leadership vacancies quickly.45
Impact — EU supervisors lose the power to block unfit candidates before they officially take up influential management roles.6
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Meeting with Tommy De Temmerman (Cabinet of Commissioner Mairead Mcguinness) and Finanssiala ry - Finance Finland and

9 Dec 2021 · Basel III

Response to Review of the Benchmark Regulation

14 Sept 2020

Please see the attached file.
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Meeting with Jyrki Katainen (Vice-President) and Finanssiala ry - Finance Finland and

14 May 2019 · Basel Implementation

Meeting with Olivier Guersent (Director-General Financial Stability, Financial Services and Capital Markets Union) and Finanssiala ry - Finance Finland and Finance Denmark

14 May 2019 · The finalization of Basel IV, and the European implementation of the new Basel requirements.

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

25 Apr 2019 · Capital Markets Union and Banking Union

Response to Review of Regulation on cross-border payments

11 Jun 2018

Dear all! I represent Swedish Bankers' Association and I hearby submit the respone from our member banks (by uploading a file) to the proposal for amending Regulation (EC) No 924/2009 as regards certain charges on cross-border payments in the Union and currency conversion charges. Best regards, Lars Rutberg Sakkunnig, Betalningar & Clearing Senior Legal Advisor, Payments & Clearing Svenska Bankföreningen/Swedish Bankers' Association Tel + 46 8 453 44 50 + 46 8 453 44 00 (exch.) Fax + 46 8 453 44 15 Mobile + 46 70 555 84 18 Visiting address: Blasieholmsgatan 4 B Box 7603---SE-103 94 Stockholm E-mail: lars.rutberg@swedishbankers.se www.swedishbankers.se
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Response to Review of the European Supervisory Authorities

23 Jan 2018

Finance Denmark, the Swedish Bankers´ Association, the Swedish Securities Dealers Association and the Danish Securities Dealers Association appreciate the opportunity to contribute to the Commission proposal on the review of the European Supervisory Authorities. Our comments can be summarized as follows: • We welcome the initiative to strengthen the governance inside the ESAs, including adding external and independent expertise. Recruitment of members to the Executive Board must not become politicized. • Non-euro-zone member states’ interests must continue to be taken into account. Clear safeguards for non-euro-zone countries in the decisionmaking system of the ESAs, most importantly the EBA should continue to exist. • One seat in the Executive Board should be dedicated to a member from a non-euro country. • The far-reaching competences of the new Executive Board speak for introducing more checks and balances. • The current funding system should be maintained. • The total amount of resources spent on supervision in the EU should not increase. • Any proposals for giving ESMA more direct supervisory powers should be preceded by careful consultations and impact assessments that show a clear benefit of such changes – a subsidiarity test. • To pass the authority to approve prospectuses from the NCAs to ESMA does not add any value to the functioning of the EU DCM market. We are against handing over supervisory powers to ESMA. • We are generally positive to initiatives strengthening the level playing field across Europe and work towards a more harmonized legal ecosys- tem in the area of collective investment funds – but we are concerned that it will raise barrier to entry if the application process is to be handled with ESMA instead of local NCAs. • We welcome the general goal of improving stakeholder involvement and increase transparency, and we therefore welcome the Commission’s proposals regarding enhancement of the level 3 procedures on guidelines and recommendations by e.g. requiring cost-benefit analysis. • Improvements are also needed at level 2 to improve transparency and stakeholder involvement in both level 2 and 3 processes. • In order to improve the stakeholder involvement and more generally to ensure satisfactory implementation processes, realistic implementation deadlines are key. • The ESAs mandates, work plans etc. need to adapt to new develop- ments and consequently, we welcome that new responsibilities in the areas of fintechs and sustainable finance are suggested. • We believe and hope that the EBA could play a stronger role in ensuring that the EU punches its true weight in global foras such as the FSB and BCBS.
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Meeting with Olivier Guersent (Director-General Financial Stability, Financial Services and Capital Markets Union) and Finanssiala ry - Finance Finland and Finance Denmark

8 Nov 2017 · Basel

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

18 Mar 2016 · Current issues in the banking sector

Meeting with Mette Toftdal Grolleman (Cabinet of Commissioner Jonathan Hill)

13 Jan 2016 · Basel IV, TLAC implementation in Europe, NSFR

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

9 Oct 2015 · EU economic policy overview

Meeting with Mette Toftdal Grolleman (Cabinet of Commissioner Jonathan Hill)

11 Jun 2015 · BSR, Priorities in the Financal Markets policy area, upcoming files in banking and International issues