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Swedbank AB (publ)

Swedbank

Swedbank is a major Nordic-Baltic banking group offering loans, payments, and savings services.

Lobbying Activity

Meeting with Arba Kokalari (Member of the European Parliament) and Finance Sweden 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 Valdis Dombrovskis (Commissioner)

18 Sept 2025 · Simplification and competitiveness

Meeting with Jörgen Warborn (Member of the European Parliament, Rapporteur)

5 Sept 2025 · Omnibus

Meeting with Adnan Dibrani (Member of the European Parliament)

3 Jul 2025 · Omnibus

Meeting with Arba Kokalari (Member of the European Parliament, Rapporteur)

15 May 2025 · AI in Financial Services

Meeting with Maria Luís Albuquerque (Commissioner) and

3 Apr 2025 · Savings and Investment Union – asset management and growth capital

Meeting with Adnan Dibrani (Member of the European Parliament)

27 Mar 2025 · ECON

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

21 Mar 2025 · AI in Financial Services

Meeting with Arba Kokalari (Member of the European Parliament, Rapporteur)

18 Mar 2025 · AI in financial services

Meeting with Matthew Baldwin (Deputy Director-General Energy) and

12 Mar 2025 · Energy Efficiency Financing - First high-level event of the European Energy Efficiency Financing Coalition

Meeting with Arba Kokalari (Member of the European Parliament) and Swedish Private Equity & Venture Capital Association

31 Jan 2025 · Capital Markets Union

Meeting with Larisa Dragomir (Cabinet of Commissioner Maria Luís Albuquerque) and NASDAQ and

20 Jan 2025 · Exchange with ImpactEurope and Swedish companies on the the Savings and Investments Union

Meeting with Andras Inotai (Acting Principal Adviser Research and Innovation) and NASDAQ and

20 Jan 2025 · Exchange of views on the advancement of the Capital Markets Union in the EU, Discussion on the experiences from the Nordic capital markets

Meeting with Didier Millerot (Head of Unit Financial Stability, Financial Services and Capital Markets Union) and Bundesverband deutscher Banken e.V. and

16 Jan 2025 · Upcoming topics in sustainable finance

Meeting with Jessika Roswall (Commissioner) and

20 Dec 2024 · sustainable finance, biodiversity, and nature credits

Meeting with Ylva Johansson (Commissioner)

23 May 2024 · -general economic situation -security aspects related to fraud

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

23 May 2024 · EU initiatives on digitalization and associated security aspects

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness) and European Savings and Retail Banking Group and

21 Feb 2024 · important files until end of mandate: CMDI, RIS, digital euro, PSR/PSD

Meeting with Jessica Polfjärd (Member of the European Parliament)

2 May 2023 · Financial legislation

Response to Alignment EU rules on capital requirements to international standards (prudential requirements and market discipline)

22 Feb 2022

Swedbank supports the responses to the Have your say consultation from the European Banking Federation, the European Savings and Retail Banking Group, and the group of three Nordic banking associations (Finance Denmark, the Swedish Bankers Association, and Finance Finland). We support the proposed application date of January 1, 2025, because it provides time for the legislative process as well as banks' and supervisors’ preparations for the implementation of the new requirements. We also support the proposal to maintain the SME supporting factor and the credit value adjustment (CVA) exemptions. Also, we support the proposed direction regarding the value-at-origination principle, where the proposal allows monitoring the value of the property and making upward and downward adjustments. LTV based purely on the value-at-origination principle would have many drawbacks, especially for mortgage exposures that tend to have longer maturities. We acknowledge that the proposal serves as a starting point for the legislative process in the European Parliament and the Council of the EU. However, we have suggestions that are further detailed in the position paper: 1. We suggest that transitional arrangements for low-risks mortgages and unrated corporates in the output floor calculation should be either made permanent or that it should be specified under which conditions they could be phased out. In addition, the transitional arrangements should be applied uniformly in the EU and not subject to national discretion. In the position paper, we argue there are structural EU specificities that cannot be addressed with transitional measures. 2. We support the application of the output floor as envisaged in the Basel text, i.e., at the highest level of consolidation. The European Commission’s proposal suggests an adequate solution for the home-host issue by introducing a mechanism of allocation of capital that stems from capital increases due to the output floor among all levels of consolidation. 3. To avoid adverse effects on trade finance instruments, we propose maintaining the CCF of 20% for trade instruments, i.e., to move the trade finance instruments from bucket 2 to bucket 4 or 5 of the Annex Classification of off-balance sheet items. Also, the use of effective maturity risk component (M) should be extended to the F-IRB approach and not be limited to the A-IRB approach that will not be allowed for large corporate exposures, according to the new rules. 4. Given the introduction of the output floor and the revision of the CRR, the double-counting of risks in the macroprudential framework should be highlighted. Swedbank proposes that it is clarified that increases of risk-weights according to Article 458 can only be applied on un-floored REA to better target the true systemic risks and to avoid undermining the policy goals of the output floor, which is to increase comparability of institutions capital ratios. 5. The position of Swedbank is that banks using the IRB approach for exposures to financial institutions should continue to use the Standardised Approach for intra-group exposures and subsequently be allowed to apply the exemptions specified in Article 113(6). Therefore, the proposed changes in Article 150 CRR should be clarified. We would also like to highlight the importance of the review of the macroprudential framework considering the finalization of the Basel III standards. The new standardised approach and the output floor will harmonize the denominator of the capital ratio, the natural next step is to harmonize application practices and limit double counting of risks in the macroprudential toolbox. Arguments and specific edits for the articles that relate to the CRR review are highlighted in Annex 1 in the attached extended position paper. In Annex 2 of the attached extended position paper, we have provided some technical comments on the proposed text that mainly relates to technical errors than substance.
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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

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

15 Nov 2021 · Basel III and AML

Meeting with Virginijus Sinkevičius (Commissioner)

28 May 2021 · To discuss the European Green Deal with a focus on sustainability from a business’s angle, also to exchange views on Taxonomy and the EU Corporate Sustainability Reporting Directive.

Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

Sustainability is one of Swedbank’s core values and we support EU sustainable finance initiatives. However, Swedbank urges the Commission to revisit the screening criteria for real estate, forestry and agriculture. Swedbank also supports the responses given by the SBA, EBF and ESBG. Acquisition and ownership of buildings built before 31 December 2020 Swedbank urges the Commission to maintain the “top 15% in terms of energy demand” criterion for acquisition and ownership of buildings built before 31 December 2020 laid out in the TEG report. The new criterion - at least class A EPC - creates uneven standards across countries and has enormous consequences to the green bond market in Sweden. EPC classification is not uniformly defined or harmonized in the EU and thus is an inappropriate standard to base screening criteria on. The range of percent of class A EPC buildings is large across the EU member states, which can be attributed partly to diverging building standards. In Sweden class A corresponds to a 50% better energy performance measure than the requirements for new buildings under Swedish law. Thus, less than 2% of the existing buildings in Sweden are class A. The consequence of this criterion is also that, in Sweden, stricter requirements will be set for existing buildings than for new buildings. This would favour new construction, which counteracts the aim of the taxonomy. A change from the current market practice of “the top 15%” to the class A EPC criterion would almost completely wipe out the eligible real estate pool that may be used in green bond issuances. In order to maintain the aim of the taxonomy, i.e. to create a unified classification system and to reorient capital to sustainable activities, Swedbank strongly argues for maintaining the “top 15%” criterion. Improved forest management Swedbank urges the Commission to return to the proposal in the TEG report i.e. existing forest management activities complying with the conditions in the TEG report should be considered taxonomy eligible. The new proposed activity, improved forest management, significantly narrows down the taxonomy-eligible forest management activities in several Nordic countries. Forest management contributes substantially to climate change mitigation even though it is not the explicit purpose of the activity. The existing forest management in Sweden absorbs about 40 million tons of CO2e annually. By adding a purpose criterion in the definition, the forest management activities defined as taxonomy-eligible will become very limited. The “additionality” criterion narrows the scope of eligible forest management activities significantly in countries with strict forest restoration and reforestation laws. Strict legal requirements in several Nordic countries make it impossible to prove that the activity could not be achieved without the funding. The requirements in the TSC of the activity not being compulsory or customary create an uneven standard and disadvantage countries with high sustainability standards. Agriculture activities The sustainable intensification goal in agricultural activities should be recognised in the TSC. There is a broad scientific consensus of the importance of increasing or maintaining agricultural yields and efficiency while decreasing the environmental burden. Thus, climate performance should be measured in proportion to the units produced. This, to avoid goal conflicts with other UN’s SDG’s goals, e.g. zero hunger. To prevent climate leakage, we urge that the Farm Sustainability Plan recognises current levels of GHG emissions and carbon sinks, in addition to the relative improvements. To improve accuracy, comparability and reduce administrative work for single farms, the TSC should include details on acceptable methodological practices and data sources. We propose that the taxonomy permits recognised standardised data to be used to measure climate impact/improvements on farm level (e.g. “Greppa Näringen”).
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Meeting with Valdis Dombrovskis (Executive Vice-President)

17 Jun 2020 · Anti-money laundering; Implementation of Basel III in the EU; COVID-19 economic response

Meeting with Stig Joergen Gren (Cabinet of Vice-President Andrus Ansip)

29 Oct 2018 · Data

Response to Institutional investors' and asset managers' duties regarding sustainability

19 Jul 2018

Please see the attached file for Swedbank's comments on the key themes relevant to the Commission proposal. Swedbank welcomes the Commission’s proposal for a regulation on the establishment of a framework to facilitate sustainable investment and sees that such a framework could create a solid legal foundation in Union law for the progressive development and market adoption of the taxonomy. The financial industry should be able to look on sustainable finance from a progressive perspective: financing should move into sustainable assets while at the same time enabling businesses and assets to become sustainable by supporting such transformations. The possible applications for the taxonomy are many, including green bonds, green lending and sustainable investment products, and its development should thus involve both capital and credit markets participants. The taxonomy and the classification system should be common for all and ensure a high standard throughout the industry and the Union. The taxonomy should from the very beginning take into account aspects already included in existing market standards; it should not be limited to environmental objectives, but incorporate sustainability broadly, including social and circular aspects. A common system for defining sustainable assets would be of great significance from a consumer protection, competition as well as from a transparency perspective. Disclosure and transparency will further facilitate the move towards sustainable finance. The harmonisation of definitions is all the more useful considering the fact that an increasing number of customers now specifically demand sustainable characteristics of their investments as well as disclosure of information to base their investment decisions on. Sustainability is a particularly noticeable trend in the Nordic and Baltic markets; in fact, a common EU taxonomy may help to avoid unnecessary complexity possibly arising from varying definitions going forward. However, the taxonomy and classification system should not be static: flexibility is needed in order to effectively promote the further development of sustainable finance while incorporating in the taxonomy the dynamics of the area of sustainable finance as well as existing technical and regional differences within the EU. The taxonomy should follow the development of the UN Sustainable Development Goals as well as that of market standards, which already today comprise green, social and broader sustainability principles. Considering the fast development in the area of sustainable finance, the taxonomy should be reviewed in detail at least once a year. The taxonomy has a number of possible applications, including green bonds, green lending and green investment products. The spectrum of sustainable and potentially sustainable assets is wide, and mapping them requires, apart from clear definitions, systematic use of data systems. Such processes also make it possible to measure the sustainability of investment products further and to achieve higher and increasingly specific levels of sustainability. Key themes, see attached file:  - Moving financing into sustainable assets  - Enabling businesses and assets to become sustainable  - Consumer protection, transparency and competition  - Green bonds, green lending and sustainable investment products  - Mapping and systematic use of data systems:  - Challenges: availability of and access to data, matching data and assets, data administration  - Measuring and improving sustainability  - Further development – circular economy, addressing social challenges, new financing needs
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Meeting with Elina Melngaile (Cabinet of Vice-President Valdis Dombrovskis)

27 Feb 2018 · Green Finance

Meeting with Stig Joergen Gren (Cabinet of Vice-President Andrus Ansip)

24 Jan 2018 · Free Flow of Data, ePrivacy, Cybersecurity, GDPR

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

3 Oct 2017 · Mifid; Macro-Prudential issues; Capital- and Financial Markets

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

6 Sept 2017 · Covered Bonds and Fintech

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

18 May 2017 · Financial services agenda

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

11 Jan 2017 · financial services agenda