Fondbolagens förening
FBF
Fondbolagens förening är en branschorganisation med uppgift att ta tillvara fondspararnas och fondbolagens intressen.
ID: 749488617800-91
Lobbying Activity
Meeting with Helene Bussieres (Head of Unit Financial Stability, Financial Services and Capital Markets Union)
5 Nov 2025 · RIS, AML, EAD
Response to Recommendation on savings and investment accounts
25 Jun 2025
The Swedish Investment Fund Associations recommendations on establishing Savings and Investment accounts Experiences from the Nordic markets show that Savings and Investments accounts can unlock the investment potential of retail savings. The Swedish Investment Fund Association (SIFA) supports the European Commissions proposal to develop a European Savings and Investments accounts blueprint. However, for the initiative to succeed, the blueprint must be sufficiently flexible to account for the diverse national tax and pension systems across the EU. To promote better saving habits and reduce the amount of household wealth sitting in deposits, Savings and Investment accounts must be simple and accessible for retail investors. Introducing more financial products, labels or layers of complexity will only discourage participation, especially from inexperienced savers. Sweden has demonstrated strong results in engaging retail investorslargely due to the introduction of simple, tax-incentivized Savings and Investments accounts (the Swedish ISK). Based on this experience, SIFA proposes the following principles, recommendations, and follow-up measures. The European Commissions blueprint should be grounded in the following three general principles: National design and implementation: Savings and Investments accounts characteristics, including tax treatment, should be determined at the member state level to ensure local compatibility. Minimum standards: The blueprint must set only minimum standards to prevent any weakening of existing national Savings and Investments accounts schemes. Reduce restrictions: Avoid strict rules on deposit limits, geography, asset eligibility, or holding periods, as they increase fragmentation and complexity. Following the above principles, the blueprint should include recommendations in six key areas: Deposit limits: To ensure that Savings and Investments accounts will effectively transform household savings into productive investments, any deposit limit should be substantial. Eligible assets: Households are a diverse group of potential retail investors. To appeal to a wide range of households with varying risk profiles, the European Commission should recommend that member states introduce Savings and Investments accounts with a broad selection of eligible assets, including listed shares and bonds, and all UCITS, ELTIFs, and retail AIFs. Geographical scope: Most European investors already show a significant home bias, so further geographical restrictions are unnecessary and counterproductive. Swedens IPO market, for example, has flourished without such limits, outperforming much larger economies in terms of listings. Holding period: Retail investors have different and evolving time horizons. A mandatory holding period would reduce flexibility and limit provider competition. The EU should recommend Savings and Investments accounts with no minimum holding period. Simple tax rules: Complex tax treatments deter participation. Savings and Investments accounts should be built around simple, easy-to-understand structures. Tax reporting: Savings and Investments accounts must be user-friendly. To reduce burden and improve accessibility, tax reporting should be handled by service providers rather than account holders. Competition and access: All licensed institutionsbanks, brokers, insurers, fund managersshould be eligible to offer Savings and Investments accounts. Investors must be able to switch providers without triggering tax penalties to ensure low costs and healthy competition. The European Commission should conduct follow-ups as more Savings and Investments accounts are introduced, with two specific measures: Good practices communication: The European Commission should gather and share successful national implementations to encourage adaptation. Monitoring: Retail participation and use of Savings and Investments accounts should be tracked, and maybe integrated with the European Semester framework.
Read full responseResponse to Revision of EU rules on sustainable finance disclosure
27 May 2025
SIFA welcomes the initiative to review the SFDR and shares the European Commissions view that the framework needs simplification, clarification, and better alignment with other sustainability-related regulations. We emphasise the importance of ensuring a realistic timeline and adequate transition period for the effective implementation of any changes to the SFDR. A key issue with the SFDR is the lack of clear legal definitions for core concepts such as sustainable investments, consider, and do no significant harm. This creates uncertainty and makes the framework difficult to apply. The Commission has attempted to provide clarifications through Q&A documents, but these are incomplete and non-binding. As a result, Member States interpret terms differently, making it difficult for fund managers to determine how their products should comply. We support the introduction of a voluntary classification system for sustainable products. To be effective, it must be based on clear, distinct categories that are easy to communicate. All categories should consistently exclude certain types of investments and activities. The system should not require prior approval but allow for supervision by national authorities. It should be designed to avoid additional disclosure requirements and instead help clarify existing obligations, partly by replacing elements of the current SFDR and reducing duplicative reporting. A clear and well-functioning system would also help prevent greenwashing. Another important issue concerns the presentation of sustainability-related disclosures. SFDR requirements are extensive, technical, and spread across various documents and websites, making them difficult for retail investors to navigate and leading to confusion rather than transparency. The framework should be simplified so that only concise and relevant information is required pre-contractually, with detailed content made available via hyperlink or cross-referencing, rather than repeated in multiple places. Aligning the format and delivery of information with the needs of retail investors would improve accessibility while also reducing the administrative burden for fund managers. In addition, distributors should be required to provide sustainability-related information through their platforms. This would help ensure that retail investors have easy access to key disclosures, regardless of the distribution channel used. We also see a need to improve the framework for reporting Principal Adverse Impacts. While the objective of highlighting negative impacts is important, implementation has proven challenging. Data is often unavailable, and the lack of harmonised methodologies makes comparisons difficult. We therefore propose reviewing and simplifying the indicators, providing guidance on how to address incomplete data, and further standardising formats and methodologies to improve comparability. Without such improvements, the reporting risks becoming a compliance exercise with limited informational value. Exclusion strategies are an important part of sustainable investing for many retail investors, particularly in Sweden. While other strategies may have a greater impact on the real economy, many investors wish to avoid certain sectors for ethical reasons. The framework should therefore ensure the necessary conditions for exclusions to be clearly communicated, e.g. through standardised reporting requirements for financial products, so that such information is presented in a consistent and understandable manner. Finally, we stress the need for alignment between SFDR and other frameworks, notably the CSRD and the Taxonomy. There is a risk that fund managers may be required to report data that companies are not obliged to provide, increasing reliance on estimates and third-party data, with negative effects on quality and costs. SFDR requirements must therefore be proportionate and aligned with the availability of underlying data.
Read full responseMeeting with Maria Luís Albuquerque (Commissioner) and
2 Apr 2025 · Savings and Investments Union – exchange with Swedish institutional investors and intermediaries
Response to Savings and Investments Union
7 Mar 2025
The Swedish Investment Fund Associations Proposal for the EUs "Savings and Investment Union" To address Europes economic challenges, a well-functioning capital market is essential for creating a competitive, transparent, and investor-friendly capital market within the EU, ensuring financial stability, innovation, and sustainable growth. A stronger investor culture with a broader investor-base among European households and individuals will help EU citizens build wealth, ensure retirement savings and finance the transition to a green and competitive economy. Strengthening EU Competitiveness Through Better Regulation The European Commission should prioritize competitiveness in regulatory processes to ensure an efficient capital market. Better impact assessments are needed to support well-founded decisions, incorporating expert input and public consultations. A well-coordinated and coherent regulatory framework is essential for streamlining implementation, permitting processes and supervision. Increasing Capital Supply Best practices from countries with strong capital markets should be shared to boost household participation. Industrial policy should be pursued without resorting to limiting investment options. Further development of the FASTER initiative is needed to remove obstacles to cross-border investments. Increasing financial literacy and investor engagement will drive competition, naturally lowering fees, as seen in markets with high participation. Defined-contribution pension systems should be promoted and introduced step by step. The European Commission should promote knowledge-sharing and best practices to support the gradual implementation of funded pension systems across the EU. Automatic reporting to national tax authorities should be enhanced as it simplifies tax compliance and thereby encourage investment in equities and investment funds. Effective Fund Regulation No new products or labels should be introduced. Regulation should focus on asset eligibility and cost transparency to increase consumer protection. A level playing field between funds and other savings products should be ensured to prevent regulatory arbitrage. All fund costs should be included in the management fee to enhance cost comparability and investor confidence. Transparency in costs related to OTC instruments and Total Return Swaps must be improved to prevent hidden fees. Income and costs from securities lending should be reported in a harmonized way. Effective Supervision Greater harmonization in the application of UCITS regulation is needed to ensure consumer protection and a level playing field for fund managers. National regulators are important since they have close contact with markets and consumers, however there should be more alignment in supervisory practices. Efficient Markets and Innovation Market-driven competition should drive consolidation, ensuring diversity and local investment. Increasing cost of operating is negative for competition even if it consolidates the market. Supporting innovation in blockchain and AI through extended regulatory sandboxes will enhance efficiency in financial markets. We recognize FIDAs potential to boost competition and drive innovation, however its implementation should align with market demand to ensure profitability for companies and trust for users. Enhancing Financial Literacy The EU should establish a European framework for financial literacy and explore the possibility of introducing requirements for Member States to promote training initiatives that enhance financial education Effective Sustainability Regulations Sustainability regulations should be harmonized to provide clarity and avoid legal uncertainty. SFDR categories should be clear, realistic, and include funds investing in transitional companies. Consistent sustainability information should be available across all investment channels.
Read full responseMeeting with Adnan Dibrani (Member of the European Parliament)
20 Nov 2024 · Sveriges och EU:s fondmarknad