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Japanese Bankers Association

JBA

The Japanese Bankers Association (JBA) is the leading trade association for banks, bank holding companies and bankers associations in Japan.

Lobbying Activity

Meeting with Elena Arveras (Cabinet of Commissioner Maria Luís Albuquerque) and Swiss Finance Council and

6 Jun 2025 · Sustainability Omnibus

Response to Taxonomy Delegated Acts – amendments to make reporting simpler and more cost-effective for companies

25 Mar 2025

We welcome the Commission's comprehensive efforts on the Omnibus package aimed at simplifying reporting requirements. This initiative significantly alleviates the burden on businesses, thereby fostering growth and enhancing the business environment, while maintaining a balanced regulatory framework. A banks balance sheet is intrinsically linked to the real economy, and consequently, reporting relies on information from counterparties. It is important that regulatory burdens do not deter financing for industries in transition, nor impose excessive information requirements on counterparties. We hope that this Omnibus package will establish a clear and robust business environment for both financial and non-financial entities, ultimately bolstering the competitiveness of the European market. Overall view on the taxonomy ・We believe that the taxonomy is a classification tool that enhances clarity and transparency of sustainable finance. To meet the objectives of mitigating greenwashing and channelling capital, the taxonomy should be used along with other important pillars of the sustainable finance framework, particularly reporting and disclosure, transition plan requirements or incentive frameworks. ・It is important that jurisdictional goals are clearly defined with incremental milestones and that these are reflected in how progress against the taxonomy is evaluated. The design and goals of the taxonomy should be consistent with this. Comments on the KPIs of the financial undertaking, the Green Asset Ratio (GAR) (Referred to the page 2-5 of the Draft delegated act -Ares(2025)1546172) ・JBA strongly supports the EUs policymakers and regulators emphasis on ensuring that the EU sustainable finance framework is usable for market participants and works effectively in achieving its objectives. However, banks face substantial challenges in assessing the Taxonomy alignment of their clients, which in turn affect the relevance of their GAR disclosure. ・GAR reporting represents a significant operational exercise for banks, requiring detailed information from clients, counterparties and investee companies. In addition to taking substantial resources for banks, it also creates burdens for their clients in providing the required information. It is therefore important to ensure that GAR reporting is providing sufficient added value and information useful for decision-making, for investors to justify its associated costs. ・Whilst amendments are made in the proposal, the GAR remains questionable in its concept and design, as it does not provide a detailed view of banks' portfolios. ・Different banks have different business models, and the current GAR formula does not enable meaningful comparison amongst banks. The ratio is significantly impacted by factors such as the proportion of business in sectors covered by the Taxonomy, the services that they provide (including the proportion of retail counterparties on their balance sheet) and the proportion of their balance sheet outside the EU (which is unlikely to be eligible for the EU Taxonomy). ・For these reasons, we therefore ask for full phaseout of the GAR requirement. ・Moreover, as the GAR only captures Taxonomy-aligned activities, it does not adequately capture financing of activities that contribute to the transition and fall within the European Commissions definition of transition finance, but which are not currently aligned with the EU Taxonomy. Accordingly, the GAR does not reflect or incentivise the provision of transition finance.
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Meeting with Stephanie Riso (Director-General Budget)

10 Dec 2024 · Presenting the EU issuance programme and discussing opportunities for investors, such as Bank of Japan, to invest in EU bonds.

Response to European Sustainability Reporting Standards

7 Jul 2023

General Comments Materiality assessment: Since the European Sustainability Reporting Standards (ESRS) currently under public comment have been expanded to include listed SMEs, transitional measures have been taken according to the attributes of the companies, and it is stipulated that the undertaking is not required to disclose non-material items based on materiality assessments except for the General Disclosures Standard (ESRS2) which is mandatory. The determination of the scope of disclosure obligations with due consideration of the feasibility of these measures should be very much welcomed. Taking the materiality assessment as a baseline promotes dialogue with internal and external stakeholders and prioritises those issues that are crucial and within the sphere of influence of the reporting company. However, the Sustainable Finance Disclosures Regulation (SFDR), the standards for financial institutions which are already in place, have no provisions for limited disclosure of materiality. Therefore, there is a possibility that there will be a data gap between financial institutions and the companies in their portfolios as the former has stricter disclosure rules. Additional data gaps may also occur between companies in their portfolios depending on the criteria for determining materiality. We expect that the requirements as well as the standards of SFDR, ESRS and the International Sustainability Standards Board (ISSB)s standards will realize consistency and interoperability in the future, with due consideration on feasibility and safe harbour rules. Interoperability: Comparable non-financial information across firms on a global scale enables a level playing field and fair treatment of all counterparties. We encourage changes that harmonise the Corporate Sustainability Reporting Directive (CSRD) with other reporting standards such as ISSB, Task Force on Climate-related Financial Disclosures (TCFD) and Taskforce on Nature-related Financial Disclosures (TNFD). We understand that the European Financial Reporting Advisory Group (EFRAG) and the ISSB have done further work to ensure that the climate related reporting standards of both EFRAG and the ISSB are interoperable. While this is welcomed, it would be helpful to clearly understand whether third country banking institutions can assume that for the elements or data points assigned and acknowledged by both EFRAG and ISSB as interoperable, whether these can indeed be used by financial institutions doing sustainability reporting as interchangeable. This clarification may result in enabling financial institutions not only to fully utilize the expertise and knowledge from extensive voluntary sustainability reporting, but also centralize and consolidate its sustainability reporting efforts across various jurisdictions where the institution operates. Implementation date: In general, the financial sector as a stakeholder has concerns on the implementation date and warns that it remains difficult to implement the ESRS on a very tight time schedule. Expecting to provide stakeholders with sufficient time to prepare for implementation given the widespread impact of regulations on operations of the stakeholders. Please see attached document for the Specific comments.
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Response to Initiative on EU taxonomy - environmental objective

28 Apr 2023

[General Comments] We welcome that the Taxonomy Regulation does not impose any obligation on investors to invest only in those economic activities that meet specific criteria laid down in that Regulation. The taxonomy should not be used for penalization purposes that may, for example, result in restricting financing for any non-taxonomy-eligible projects, but rather, it should be used to foster and support taxonomy-eligible projects. We believe the EU should avoid creating a trend where only those in the green list are "good" and others that are not in the green list are "bad". Instead, the taxonomy should be used for fostering and supporting taxonomy-eligible projects. A well-balanced framework should be developed for both developed and emerging countries by sharing a universal and global principle. Such a framework shall lead to accommodation for a variety of taxonomies developed in a harmonized way to the extent possible, and these taxonomies should be introduced in ways that reflect the economic or energy-related situations of each country and jurisdiction. An excessive and prescriptive taxonomy might impede innovation. In order to create an environment for fostering creativity and innovations of the private sector, we consider taxonomy to be a flexible framework that should be regularly reviewed to reflect current trends. The EU should guide the real economy sectors on how they can achieve net zero by leveraging transition technologies currently available in a sufficiently ambitious but realistic way. In this sense, the EU should clearly indicate how the EU ensured the scientific evidence, economical and operational viability, and readiness of supply chains regarding the proposed TCSs in the EU taxonomy. [Specific Comments] I couldn't fit all of our comment here, so as for the Specific Comments, please check the attached file.
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Response to Alignment of EU rules on capital requirements to international standards (review processes)

14 Feb 2022

The Japanese Bankers Association (JBA) welcomes the opportunity to provide feedback on the European Commission’s draft Capital Requirements Directive VI (“CRD VI” ). In this letter, we set out to respond to the proposed changes to the supervision of third country branches (TCBs) in the EU and to the proposed changes to the cross-border provision of banking services by third country undertakings. 1. General comments The JBA supports the European Commission’s efforts towards further harmonising supervisory powers and tools across EU Member States, as this will bring enhanced transparency and strengthen supervision across the EU banking landscape. Notwithstanding our general support for the objectives of the Commission’s proposals in CRD VI (the Proposals), we do have several significant concerns regarding the provisions of the Proposals in relation to cross-border business and TCBs, which are highlighted herein. These provisions must be balanced with the objectives of bringing benefits for corporations and financial institutions through improved market access, choice and reduced friction in financial services within the EU. As currently drafted, however, we believe there will be significant adverse impact on the ability of TCBs to provide services to EU clients, leading to a reduction in choice for European businesses and a reduction in liquidity in EU financial markets. Japanese banks are highly invested in and committed to the EU, helping to finance the European economy by providing EU clients with various kinds of financial service through TCBs in certain EU Member States. We urge the European Commission to consider the critical contribution which the Japanese TCBs make to the European economy, and to strike the right balance between EU policy objectives. Please refer to the attached file for details of the comment.
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Meeting with Tommy De Temmerman (Cabinet of Commissioner Mairead Mcguinness)

14 Feb 2022 · Branches of third-country banking groups