Nordic Financial Unions
NFU
Nordic Financial Unions (NFU) is an organisation for co-operation between trade unions that organises employees in the banking, finance and insurance sectors in the five Nordic countries.
ID: 4129929362-47
Lobbying Activity
Response to Digital package – digital omnibus
13 Oct 2025
The European Union has developed an ambitious but fragmented digital regulatory framework, spanning the AI Act, the Data Act, the Cyber Resilience Act, and the Platform Work Directive. While each instrument addresses essential aspects of the digital transition, their cumulative effect has been overlapping obligations, administrative duplication, and divergent enforcement across Member States. The Digital Omnibus Initiative presents an opportunity to create coherence and restore the balance between innovation, human rights, and social sustainability. From a trade union perspective, the existing frameworks procedural safeguardssuch as transparency and human oversightmust evolve into substantive empowerment for those subjected to algorithmic management. Algorithmic tools now reach far beyond platform work and increasingly shape employment in sectors like finance, influencing recruitment, task allocation, monitoring, and evaluation. These systems risk transforming workers into data points within what scholars have termed digital dehumanisation. EU digital policy, historically rooted in consumer protection, conceptualises harm through individual rather than collective rights. This imbalance has limited attention to the social dimension of sustainability, particularly fair working conditions, labour rights, and collective protection for all market participants. The Union must therefore extend its protective scope to recognise the structural vulnerabilities created by AI in the workplace and the states duty to mitigate them. The NFU argues that simplification must not mean deregulation, but rather integration and coherence. A unified Digital Governance Framework should merge the shared principles of data governance, cybersecurity, and AI into a single operational model, reducing redundancy while maintaining accountability. In the employment sphere, a dedicated legal instrument should consolidate and strengthen rights under Directive (EU) 2024/2831 on Platform Work, extending them to all forms of AI-driven labour management. The NFU highlights the particular importance of Articles 6(2) and 2(11) of the AI Act. Article 6(2) and Annex III classify AI systems used in employment and worker management as high-risk, triggering obligations on risk management, transparency, and fundamental-rights protectionthereby giving trade unions a concrete legal basis for participation in oversight and collective bargaining. Yet, the derogation clause in Article 6(2) could weaken these safeguards by allowing providers to downplay risks. This, combined with the reality that supervisory authorities often apply risk-based supervision due to limited resources, may result in violations going unaddressed and high-risk systems being deployed without proper safeguards, contrary to legislative intent. Article 2(11), defining the deployer as the entity using an AI system under its authority, is equally critical as it clearly identifies the employers responsibility. This definition supports the role of trade unions in holding employers accountable for compliance, ensuring that transparency and human oversight become genuine tools of empowerment rather than formalities. To translate legal frameworks into effective protection, the NFU proposes introducing Human Dignity Impact Assessments to evaluate not only privacy or data risks, but also the effects of automation on autonomy, psychological well-being, and freedom from coercion. These should be participatory processes involving workers, unions, and civil society. Moreover, competence-building and continuous training must become integral to all human-oversight mechanisms to ensure transparency leads to empowerment. The institutionalisation of algorithmic co-designwhere workers and their representatives are involved in the creation, testing, and evaluation of AI systemswould further democratise technology and reflect the EUs human-centric approach to AI. Simplification should also respect proportionality.
Read full responseResponse to 28th regime – a single harmonized set of rules for innovative companies throughout the EU
30 Sept 2025
If the European Commission chooses to put forward a proposal for a 28th regime for company law rather than prioritising deeper integration of the Capital Markets Union and the Savings and Investment Union, NFU recommends that such an initiative follow the approach taken by the European Parliaments INL draft report. The regime should be strictly complementary to national company laws and designed to reduce genuine regulatory fragmentation that impedes cross-border business growth. It should not extend into the field of labour law or social security systems, which remain fundamental to Europes identity, resilience and long-term success. Only by striking this balance can the EU strengthen the Single Market in a way that supports innovation and competitiveness while preserving the fairness, stability and trust that underpin sustainable economic growth.
Read full responseMeeting with René Repasi (Member of the European Parliament, Rapporteur)
26 Sept 2025 · Omnibus, 28. Regime
Response to Evaluation of the Whistleblower Protection Directive
18 Sept 2025
In the following NFU concentrates on remaining gaps and areas where our member unions see room for stronger protections through further-going harmonisation. Overall NFU concludes that the standard has been raised compared to the pre-Directive situation. NFU suggest revising and amending the Directive: Adequate Coverage: Protection must extend to all categories of workers: permanent, temporary, short-term, consultants, interns. This ensures that the most precarious workers, often the least likely to speak out are protected. Anonymity: While formally recognised, in practice employers can sometimes still identify whistleblowers. The Danish Working Environment Authority model shows stronger anonymity is possible. Whistleblowers must be able to report securely and remain anonymous, unless disclosure is legally required in judicial proceedings. Employers should be prohibited from inquiring into the identity of whistleblowers. Authorities should provide multiple secure channels: written, online, telephone (recorded or documented), in-person. Online reporting systems must guarantee data protection and whistleblower confidentiality. Burden of proof: Only partially reversed; unlike in workplace environment law, there is no full reversal obliging the employer to prove actions are not retaliatory. Reporting should be possible based on reasonable suspicion, without requiring hard evidence from the reporting person. Compensation: Remedies remain weak (69 months salary), far below what would be dissuasive in financial services. Compensation must be substantial and deterrent, we propose a benchmark of 24 months salary. Subtle retaliation: Informal sanctions (task reassignment, stalled promotion, isolation) remain under-addressed. Confidentiality breaches: No clear sanctions exist if a whistleblowers identity is compromised. Towards Stronger EU Harmonisation With the Directive now forming a baseline, NFU argues for stronger, practical minimum standards across the EU: Guaranteed anonymity vis-à-vis employers, Full reversal of the burden of proof, Dissuassive compensation standards, Explicit coverage of subtle retaliation, Harmonised procedures for cross-border cases, Minimum institutional quality requirements (independence, deadlines, external channels, access to legal/psychological support).
Read full responseMeeting with Maria Luís Albuquerque (Commissioner) and
25 Mar 2025 · Exchange on supplementary pensions and regulatory developments
Response to Savings and Investments Union
7 Mar 2025
NFU welcomes the European Commissions efforts to enhance the EUs SIU and financial stability but emphasizes the need for a balanced approach that protects employees, strengthens workplace pensions, and promotes fair access to capital. NFU contends a strong employees perspective: Financial employees must be at the center of discussions on further harmonisation and more integrated supervisory rules. We urge policymakers to reinforce co-determination mechanisms in Pillar II pension schemes to ensure employee participation in financial decision-making. Social partners can together contribute to increase more cost-efficient and sustainable pension products through meaningful social dialogue. The success of financial literacy initiatives depends on ensuring financial advisors provide unbiased, conflict-free guidance to investors. We rec-ommend a robust framework of remuneration models, which do not un-dermine fair and client-centric financial advice. The continued presence of financial advisers also bridges potentially the differences in financial literacy and digitalisation across EU member states. Retail clients represent a heterogeneous group that includes mass consumers, sophisticated investors, and SMEs. As the RIS and the Insolvency directive recast are being negotiated, NFU would like to remind negotiating co-legislators that both legal frameworks should aim to make the EU rulebook more proportional and less complex, addressing issues such as information overload for retail clients The NFU proposes that the customary 3-year review clause is changed into 5 years because, as three years is much too short time period to see all the effects of legislative acts. Especially considering that it is unclear exactly which expectations the sector must live up to in order for the European Commission not to further regulate. The Nordic capital markets offer a strong blueprint for SME funding, but further integration requires further harmonisation to eliminate barriers and to avoid double taxation. NFU stands ready to collaborate with the Commission to achieve a regulatory framework that fosters capital market growth while upholding worker rights and financial transparency.
Read full responseMeeting with Adnan Dibrani (Member of the European Parliament)
2 Oct 2024 · Konsumentskydd, hållbarhet och arbetsvillkoren för anställda inom finanssektorn
Meeting with Aura Salla (Member of the European Parliament)
1 Oct 2024 · Introductory meeting, Nordic Financial Union's views on EU regulation
Meeting with Asger Christensen (Member of the European Parliament)
25 Sept 2024 · Finance sector priorities
Meeting with Michael Hager (Cabinet of Executive Vice-President Valdis Dombrovskis)
9 Apr 2024 · EU financial policy, Nordic-Baltic financial sector, Capital Markets Union
Meeting with Eero Heinäluoma (Member of the European Parliament, Shadow rapporteur)
17 Oct 2023 · Retail investment strategy
Meeting with Eero Heinäluoma (Member of the European Parliament, Shadow rapporteur)
23 May 2023 · Capital Markets Union Package and the Retail Investment Strategy (ECON)
Response to Initiative on EU taxonomy - environmental objective
3 May 2023
NFU is providing feedback on Annex II and Annex IV to the Environmental Delegated Act.
Read full responseMeeting with Axel Voss (Member of the European Parliament, Shadow rapporteur) and Association Française de la Gestion financière and
9 Feb 2023 · Corporate Sustainability Due Diligence
Response to Institutional investors' and asset managers' duties regarding sustainability
19 Jun 2018
Nordic Financial Unions (NFU) supports the Commission’s aim of including ESG considerations in the advisory process under IDD (Directive EU/2016/97 and Delegated Regulation EU/2017/2359), both in the customer profiling and product selection.
NFU believes that finance employees are key levers to facilitate the transition to green finance. It is crucial that the players in the financial industry are competent and updated on how ESG-themes affect investment, society and customers. As recognised under IDD, continuous training and development must be ensured for the employees for them to possess an appropriate level of knowledge and competence in relation to the products offered. Furthermore, employees should be given adequate time and resources to be able to provide all relevant information to customers about the products that they provide. As ESG considerations is a new part of the suitability assessment, it is crucial that education on sustainability and accountability is part of different training and competence programs within the financial institution. NFU stresses that this should be a natural part of company-based training for employees.
The results of two studies conducted by NFU (Performance Measurement Systems (2016) & Coping with Compliance (2018)) showed that finance employees are under high pressure at work. We know that the pressure on employees has increased and that employees are faced with extensive regulatory requirements and high sales targets as they are measured in their work every day. Add the downsizing of banks and layoffs to the equation and you find a situation where fewer employees are expected to manage higher regulatory requirements as well as their performance targets in a pressured working environment. Having that in mind, NFU again wants to stress the importance of the employees being given the time to achieve the competence needed to fulfil the aim of the Commission with the new demand of ESG in the suitability assessment.
Read full responseResponse to Institutional investors' and asset managers' duties regarding sustainability
19 Jun 2018
Nordic Financial Unions (NFU) supports the Commission’s aim of including ESG considerations in the investment and advisory process under Mifid II, as part of the duties towards clients.
NFU believes that finance employees are key levers to facilitate the transition to green finance. It is crucial that the players in the financial industry are competent and updated on how ESG-themes affect investment, society and customers. As recognised under MiFID II, employees must possess an appropriate level of knowledge and competence in relation to the products offered. Investment firms should allow their staff sufficient time and resources to achieve that knowledge and competence and to apply it in providing services to clients. As ESG considerations is a new part of the suitability assessment, it is crucial that education on sustainability and accountability is part of different training and competence programs within the financial institution. NFU stresses that this should be a natural part of company-based training for employees. That the firms must provide their staff with training on these issues is also recognised under General Guideline 11 with paragraphs 96-100 in the recent ESMA Guidelines on certain aspects of the MiFID 2 suitability requirements.
The results of two studies conducted by NFU (Performance Measurement Systems (2016) & Coping with Compliance (2018)) showed that finance employees are under high pressure at work. We know that the pressure on employees has increased and that employees are faced with extensive regulatory requirements and high sales targets as they are measured in their work every day. Add the downsizing of banks and layoffs to the equation and you find a situation where fewer employees are expected to manage higher regulatory requirements as well as their performance targets in a pressured working environment. Having that in mind, NFU again wants to stress the importance of the employees being given the time to achieve the competence needed to fulfil the aim of the Commission with the new demand of ESG in the suitability assessment.
Comments on Amendments to Delegated Regulation (EU) 2017/565;
Art 1 (10). NFU is pleased to see the inclusion of social investments and especially the recognition of taking labour relations into consideration.
Art 1 (11). NFU is pleased to see the inclusion of good governance investments. NFU would however strongly suggest replacing “…, employee relations, remuneration of relevant staff….” With “collective bargaining & social dialogue”. It is otherwise unclear what is meant with employee relations and remuneration of relevant staff. It is more reliable to establish if there is collective bargaining, rather than measuring the more subjective and unclear “employee relations”. Collective bargaining ensures that there is social dialogue and a collective agreement at the company in question and that employees are recognised as important stakeholders. Social dialogue is recognised by the European Commission as improving and boosting economic competitiveness and social cohesion at the same time. NFU therefore advises the Commission to instead write collective bargaining & social dialogue.
NFU however asks for a clarification on why these two above discussed points (10) and (11) not are referred to as amendments as with the earlier points (7-9) are. Measures to assess the social impact of investments go hand in hand with efforts to address environmental concerns and climate change. It is therefore noteworthy that they seem to be excluded from the amendments to Delegated Regulation (EU)2017/565. It appears as if the Commission only wants to include the definition of what is an environmentally sustainable investment is as an amendment and neglect the Social- and Good governance-considerations.
Read full responseMeeting with Paulina Dejmek Hack (Cabinet of President Jean-Claude Juncker)
3 May 2018 · Impact of financial regulation
Response to Review of the European Supervisory Authorities
19 Apr 2017
The work carried out by the European Supervisory Authorities constitutes a good basis for further actions on financial stability and towards ensuring a level playing field of supervision in the EU.
NFU finds that there is at times a gap between what is decided on level 1 and how this is incorporated at level 2 by the ESA’s. The EBA guidelines on sound remuneration policies from 2015 (CRD-4) published in late December 2015 showed that EU legislators are often not familiar with the Nordic model. In a relevant consultation done by the EBA earlier same year, NFU raised issues such as the right to free collective bargaining. In the final guidelines EBA analysed some of the specific points – where one of the points was collective bargaining and the compatibility of EBA guidelines with other legal acts – namely Article 28 of the EU Charter of Fundamental Rights and Article 153(5) of the TFEU. What EBA found was that “Neither the CRD nor EBA GL on sound remuneration polices are contrary to the Article 153(5) of the TFEU, since they do not set a uniform level of pay within the European Union or the equivalence of the constituent part of pay. With regards to article 28 of the EU Charter of Fundamental Rights EBA means that “… the right to collective bargaining should be exercised within the framework laid down by the EBA guidelines on sound remuneration policies and made no alteration to the published guidelines. NFU believed the guidelines showed a severe lack of understanding from the European Supervisory Authorities on how wages are formed and regulated – and the important role of social partners. Together with UNI Europa Finance, NFU created an alliance with the European Banking Federation on the issue, speaking with one voice towards the European Commission. At the same time, EBA released another piece of draft guidelines on remuneration requirement for sales staff. These guidelines are more general and cover all sales staff in finance. In the consultation reply to the EBA, NFU put a lot of effort into explaining the specificities of collective bargaining and the problems of the EBA interpretation in the previous released guidelines. In September 2016, the EBA published the final guidelines based on consultation replies and writes that “… the EBA underlines that these Guidelines, like any other Guidelines, apply notwithstanding any other applicable rules, including social and labour law, and therefore do not prevent the right for collective agreement to take place.” NFU was pleased to see that the EBA finally took our concerns into consideration and changed their interpretation of collective bargaining based on our advocacy work. NFU consider this to be a great win for NFU and the right for to collective bargaining. NFU would therefore urge the ESAs to continue to acknowledge this important right. The European Union has no right to interfere with collective bargaining systems as set down in article 153.5 of the Treaty on the Functioning of the European Union. Pay and wages is not for any EU institution, authority or body to deal with.
NFU believes that it is important to emphasize the importance of the Stakeholder Groups that are a valuable democratic element of the ESAs. Regardless of the future ESA design it is imperative to have SGs as a part of it. The future composition of SGs should be more balanced between the stakeholder constituencies. In the present set-up, there is an overweight of especially industry and consumer representatives, while the employees are underrepresented. Secondly, regarding the boundaries of the ESAs’ tasks and powers: It seems to be increasingly necessary to consider a widening of those boundaries, whereby the ESAs are given authority not only in relation to the traditional financial sector. Tasks and power of ESAs should be directed towards actual activities, rather solely on how they are organized. The mandate for the ESAs should continue to promote transparency and convergence.
Read full responseMeeting with Edward Bannerman (Cabinet of Vice-President Jyrki Katainen)
21 May 2015 · Financial services outlook