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Swedish Securities Markets Association (Swedish: Föreningen Svensk Värdepappersmarknad)

SSMA (Swedish: SVPM)

The Swedish Securities Markets Association represents banks and investment firms to promote competitive securities markets.

Lobbying Activity

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

13 Nov 2025 · Savings and investment union

Meeting with Stéphanie Yon-Courtin (Member of the European Parliament, Rapporteur) and Insurance Europe and AMUNDI AM

6 Nov 2025 · Retail investment strategy

Meeting with Arba Kokalari (Member of the European Parliament)

28 Oct 2025 · Savings and Investments Union / Retail Investment Strategy

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

24 Sept 2025 · Nordic Finance evening -vastaanotto

Meeting with Alice Guedel (Cabinet of Commissioner Maria Luís Albuquerque), Cristina Dias (Cabinet of Commissioner Maria Luís Albuquerque)

22 Sept 2025 · Discussion on SIU in general and the forthcoming blueprint on investment savings account

Meeting with Alice Guedel (Cabinet of Commissioner Maria Luís Albuquerque), Cristina Dias (Cabinet of Commissioner Maria Luís Albuquerque)

22 Sept 2025 · Exchange on the Savings and Investments Union package

Swedish Securities Markets Association Urges National Control for Investment Accounts

7 Jul 2025
Topic — This consultation develops a European blueprint for savings products to boost retail investment.
Message — The association requests that investment accounts be designed nationally rather than through a single EU model. They advocate for simple tax rules and removing restrictions on deposits, geography, and assets to maximize participation.12
Why — National implementation allows the association to protect its successful domestic investment account model.3
Impact — European companies lose if investors are not incentivized to prioritize funding local industries.4
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Meeting with Maria Luís Albuquerque (Commissioner) and

2 Apr 2025 · Savings and Investments Union – discussion with Swedish financial market infrastructure representatives

Meeting with Maria Luís Albuquerque (Commissioner) and

2 Apr 2025 · Savings and Investments Union, financial literacy

Response to Savings and Investments Union

6 Mar 2025

SSMA supports the new EC focus on competitiveness. In fact, a main characteristic of the well-functioning capital market in Sweden is its high degree of competition, between big and small market participants, providing clients with a broad range of investment services (advice, execution only etc.) and investment products (funds, shares etc.). This competitive environment is one reason why Swedish investment funds have amongst the lowest fees in the EU. We think that the EC should in its work on the SIU take a market-based approach (bottom up, not top down). Convergence may be needed in some areas e.g. to facilitate cross-border activities but at the same time capital markets in the EU are different, e.g. as regards currency, T2S, number and types of active retail investors, level of digitalization, and financial literacy. We must avoid a one-size-fits-all approach and should facilitate for Member States (MS) to learn from each other (best practice), as many actions must be taken at MS level. We agree that increased retail (and institutional) engagement is crucial for EU capital markets. However, we do not believe that new EU investment products (with or without labels) will necessarily achieve this objective. Previous experiences of EU products, e.g. the PEPP, have not been very successful. The design of investment products should be left to market participants and not legislators. We even see a risk that such proposals could have a distorting effect on competition. A properly designed tax incentive can be a good way of encouraging households to invest. As mentioned by Draghi, the Swedish ISK could serve as a model (but is not a silver bullet). A main feature of the account, besides a certain tax advantage, is that it makes it very easy for retail clients to invest. There is no need to declare transactions or profits/losses relating to trading on the ISK. It also allows clients to invest in different financial instruments, e.g., investment funds and shares, without geographical restrictions and regardless of type of distribution. The complexity of the EU regulatory framework creates barriers of entry for retail clients and operational risks for investment firms. SIU should serve to simplify investor protection rules, e.g. as regards disclosures, client categorization, onboarding, and reporting. Existing incl. ongoing legislation such as RIS, as well as future proposals should be part of a simplification review. Financial literacy is crucial for retail investors engagement on capital markets and should be prioritized both at MS and EU level. Our experience is that financial literacy is best achieved when education is combined with learning by doing. Building on the work done by the OECD and EC, we suggest the establishment of a platform at EU-level where public and private actors can share initiatives to improve financial literacy. To improve European market infrastructure, we support further increasing the interoperability between infrastructure providers and to continue the ongoing work to further increase harmonization of post-trade processes in the EU, considering where relevant national specificities. As regards exchanges, a key issue is how to best encourage trading, improve market liquidity, and tackle barriers to cross-border investments, e.g., withholding tax. We support the ambition to simplify the EU-rule book and consider that the SIU should include an analysis and review of the legislative process. It is important to improve impact assessments at all levels, include consumer testing, avoid gold-plating, and limit the number and complexity of measures at level 2 and 3. Implementation problems are often caused by EU rules not being sufficiently analysed in advance as regards scope and how they interact at a horizontal level. We support giving the ESAs power to issue no-action letters and increased supervisory convergence which does not necessarily mean more centralisation of the EU supervisory system.
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Meeting with Arba Kokalari (Member of the European Parliament)

19 Feb 2025 · 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 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 Adnan Dibrani (Member of the European Parliament)

26 Sept 2024 · Finansiella frågor

Response to Applying a unique identifier for public transparency of OTC derivatives

10 Jul 2024

Stockholm 10 July 2024 SSMAs comments to the European Commissions Have Your Say consultation regarding OTC derivatives identifier. The Swedish Securities Markets Association (SSMA) welcomes the opportunity to respond to the European Commissions (EC) Have Your Say Consultation on OTC derivatives identifier to be used. General comments SSMA members experience is that all regulatory changes and updates especially for reporting standards will lead to high implementation costs. There are usually several connected systems and routines that need to be updated and integrated to work properly. More complex changes will lead to higher implementation costs. SSMA therefore think it is important to have changes with the least technical impact to keep the costs as low as possible. It is also important that changes are coordinated with other updates/changes in other legal frameworks to prevent implementation of related changes at different dates. SSMA also want to take the opportunity to welcome all initiatives to a more general long-term plan on how to develop and simplify reporting across all different legal frameworks. We think much efficiency and cost saving could be achieved by harmonizing reporting standards for all different reporting mechanisms. It is also important that any changes within EU are harmonized with international standards. Specific comments SSMA responded to the previous consultation and favoured the UPI+ solution and we also believe that most respondents had the same view. SSMA is of the opinion that in the future more weight should be given to input provided in formal consultations rather than more informal discussions in technical workshops, as transparency is essential when taking decisions like these. Even though SSMA wanted to have UPI+ for simplicity reason we see no major obstacle to use and implement the modified ISIN instead. SSMA however have some concerns regarding the implementation of the modified ISIN: 1 SSMA is of the opinion that this change should in the first step only be done for transparency reporting. Any changes to transaction reporting must be coordinated and harmonized with other reporting mechanisms, especially EMIR reporting. 2 SSMA presumes that this update does not lead to forced updates or changes in existing instruments identifier codes. 3 SSMA also stress that there must not be any historical or backward updating of instrument identifiers. That could lead to severe problems. 4 SSMA is of the strong opinion that all ongoing regulatory updates related to reporting in the Mifir review are coordinated in time so that they come into force at the same date. Some of the related changes are updates linked to CTP, DPE and TRS reference data. 5 SSMA believes it is very important that any changes within EU are harmonized with international standards. Otherwise, there is a risk that the same instrument needs to have different identifiers for different purposes and that will create many problems.
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Meeting with Jessica Polfjärd (Member of the European Parliament)

25 Jan 2024 · RIS

Swedish Securities Markets Association urges single EU tax portal

18 Sept 2023
Topic — A proposal for a common EU-wide system for withholding tax relief at source.
Message — The association advocates for a single EU-wide portal for registration and reporting to avoid complex national systems. They suggest extending the scope to all securities issued by central depositories to reduce management complexity. They also request a 24-month delay following the adoption of laws to allow for technical development.123
Why — A centralized system would lower operational costs and reduce the risk of reporting errors.4
Impact — Investors may face worse conditions if countries restrict tax relief based on ex-dividend dates.5
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Swedish Securities Markets Association urges more proportionate investment rules

28 Aug 2023
Topic — European Commission consultation on measures to increase retail investor confidence and market participation.
Message — The SSMA requests a minimum 24-month implementation period following the finalization of technical standards. They oppose the proposed partial ban on inducements for execution-only services. Additionally, they call for excluding corporate bonds and hedging derivatives from investor disclosure requirements.1234
Why — This would allow firms to avoid disruptive business model changes and minimize rising compliance costs.567
Impact — Active and sustainable fund managers lose out as rigid cost benchmarks favor passive products.89
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Swedish securities association demands fair fees for ESG ratings

13 Aug 2023
Topic — EU initiative to strengthen the reliability and transparency of ESG ratings.
Message — SSMA supports exempting investment research from these rules to avoid overlapping requirements. They request robust regulations on fees and transparency regarding rating methodology changes. Providers must allow companies to verify and correct information before publication.123
Why — The association avoids redundant regulation and protects members from excessive market data costs.45
Impact — Dominant global providers might lose the ability to charge non-transparent bundled fees.6
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Response to Facilitating small and medium sized enterprises’ access to capital

24 Mar 2023

Please see attached for the Swedish Securities Markets Association's (SSMA) response to the EU Commission's Listing Act proposal.
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Response to Facilitating small and medium sized enterprises’ access to capital

24 Mar 2023

Please see attached for the Swedish Securities Markets Association's (SSMA) response to the EU Commission's Listing Act proposal.
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Swedish Securities Markets Association opposes forced clearing relocation policy

20 Mar 2023
Topic — A review of EU regulations governing central counterparties and derivative clearing services.
Message — SSMA rejects the active account requirement, labeling it a forced relocation policy. They demand exemptions for market making and client clearing to avoid conflicts. The association also calls for making margin exemptions for equity options permanent.123
Why — These measures would allow Swedish banks to avoid high costs and maintain global competitiveness.45
Impact — Smaller firms might be forced to stop hedging due to unproportionate regulatory costs.67
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Response to Central securities depositories – review of EU rules

20 May 2022

SSMA’s comments focus on CSDR article 7 and the delegated regulation (EU) 2018/1229 (the RTS). We are of the opinion that penalties is a better tool for addressing settlement fails than mandatory buy-ins (MBI) and would therefore recommend a removal of the overall MBI provisions. Prescribing a mandatory obligation for a buyer to make buy-ins is a radical intervention in the contractual law and the relationship between contractual parties, in particular as the pre-defined mandatory obligation to remedy the failure is placed on the non-failing party. A better solution would be to adjust the penalty rates for market segments where the settlement ratio is unsatisfactory. If a full removal of MBIs is not deemed possible, we support the idea of a two-step approach, but some clarifications of the intended process is needed. In general, SSMA urges the Commission to be very conscious of ensuring legal clarity and consistency between the level 1 regulation, level 2 delegated acts/RTS and level 3 guidelines. As concerns SDR, most of the issues that have arisen are in relation to the provisions in the RTS, rather than the level 1 text. We see a risk that that could also be true for the parts where the Commission would get new mandates for level 2 regulation. There is still uncertainty as regards the scope of CSDR. Several obligations are placed on a “trading party”, defined as a party acting as principal in a securities transaction, but a principal is not defined and the term is used inconsistently. In any case, “Trading party” should be clearly defined as to not include retail investors; in the Swedish market, settlement of transactions to some extent involves i.a. retail clients with securities accounts at the CSD level. We would welcome a removal of the mandatory need for appointing a buy-in agent, as indicated in recital 11, and think that it should be made clear that there is no obligation to use an agent to carry out a buy-in. The meaning of “settlement fails are caused by factors not attributable to the participants to the transaction or for operations that do not involve two trading parties” in the proposed article 7.2 is unclear and we would welcome a clarification in the level 1 text. Any decision by the Commission according to article 7.2a should be limited to only the relevant subcategories of a national market, to avoid unnecessary distortions. Also, it is not sure that the criteria in article 7.2a (b) are appropriate to make a well-founded decision. Few markets are comparable and deep knowledge about the local markets’ specificities and practices is needed to make such a decision. We support the attempt to develop a real pass on mechanism but there is a need to clarify the responsibilities in the delivery chain. Regarding the proposed article 7.13a, it is important that any suspension decisions be taken promptly, and if needed, with retroactive effect to avoid threats to financial stability or the orderly functioning of the market. With regards to the proposed passporting changes we are concerned that the removal of the possibility for the host supervisor to refuse the passport may result in additional risks to investors, as CSDs need to be able to support issuance in according with the issuer’s national laws (primarily in relation to company law and tax law). As these are not harmonised across the EU, the home supervisor cannot assess the CSD’s ability to comply with the host country’s requirements. With regards to the proposed changes to the requirements on CSDs providing banking-type ancillary services. We believe that the CSDs’ critical role as central market infrastructures for core functions should remain adequately protected from any additional risks, such as banking risks, credit risks or market risks, that are normally associated with the provision of banking services.
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Swedish Securities Markets Association opposes CSDD civil liability regime

6 May 2022
Topic — New EU rules forcing companies to identify and mitigate environmental and human rights risks.
Message — The association strongly opposes the introduction of a new civil liability regime. They demand alignment with existing financial regulations to prevent overlapping administrative burdens. The term potential should be deleted to avoid disproportionate legal uncertainty.123
Why — Avoiding these rules would reduce unpredictable litigation risks and compliance costs for banks.4
Impact — Environmental and human rights victims lose a specific path for claiming damages.5
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Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness) and Finanssiala ry - Finance Finland and

5 Nov 2021 · MiFID/MiFIR

Response to Strengthening the consideration of sustainability risks and factors for financial products (Directive (EU) 2017/593)

6 Jul 2020

See attachment with SSMA full response. Key issue: The SSMA has several concerns in respect of the proposed new definition of “sustainability preferences” in Article 1 and 2 of MiFID II delegated acts. In particular, the following issues should be further analysed: The SFDR distinguishes between on one hand financial products with sustainability objectives (Article 9) and on the other hand financial products that promote ESG-characteristics (Article 8). Furthermore, SFDR defines “Sustainable investments” (Article 2.17). However, the proposed MiFID II definition of “sustainability preferences” introduces a new type of instrument which, in addition to the requirements in Article 8 SFDR, either (i) has sustainable investment as their objectives or (ii) consider principle adverse impacts. In our view, this definition creates an unfortunate sub-class of article 8 products which cannot be considered as sustainable investment products under MiFID II thereby forcing many manufacturers of financial products to re-engineer Article 8 products by the MiFID II definition. This conflicts with the message under SFDR, i.e. that the intention with the regulation, is not to change current investment strategies of managers. The MiFID II definition of sustainability preferences in art 2 refers to “financial instruments” and not “financial products”, which is the term used in SFDR. As a result, the MiFID II rules will include instruments for which financial market participants do not have obligation to publish data under SFDR, such as bonds and shares, or the obligation to categorise these instruments in accordance with the requirements in article 2.17, 8 or 9. This will lead to implementation challenges that must be carefully analysed by the Commission. Moreover, by using the term “financial instruments”, instruments which are not even used for investment purposes are in scope of the MiFID II rules, i.e. derivatives used for hedging. We also note that other sectorial legislation proposed by the Commission as part of the same ESG-package have been drafted differently. In fact, in IDD, UCITS, AIFMD and Solvency II, the definition of “sustainability preferences” refer to “financial products” and not “financial instruments”. No explanation has been provided in the consultation paper for why another term is used to define “sustainability preferences” in MiFID II compared to other sector legislation such as IDD. Another issue which needs to be further considered is the fact that under MiFID II, portfolio management is an investment service whereas “a portfolio” is a financial product under SFDR. Under the current drafting, a significant number of products covered by Article 8 and 9 SFDR will therefore not be included in the proposed new MiFID II regime on level 2. Is the meaning of the proposed Article 2 that the investor shall be asked about his/hers sustainability preferences on the portfolio (which will not be covered by the definition in the proposed Article 2) or of the underlying financial instrument that the portfolio may or may not invest in (which will be covered by the definition in the proposed Article 2)? Based on the above concerns, the SSMA proposes the following amendments to the definition to “sustainability preferences” in Article 1 and 2 of MiFID II delegated acts: “(7) ‘sustainability preferences’ means a client’s or potential client’s choice as to whether either of the following financial instruments should be integrated into his or her investment strategy: (a) a financial instrument that has as its objective sustainable investments as defined in Article 2, point (17), of Regulation (EU) 2019/2088 of the European Parliament and of the Council; (b) a financial instrument that promotes environmental or social characteristics as referred to in Article 8 of Regulation (EU) 2019/2088".
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Meeting with Paulina Dejmek Hack (Cabinet of President Jean-Claude Juncker)

4 Sept 2019 · Capital Markets Union

Response to EU small listed companies Act

19 Jun 2018

The SSDA welcomes the initiative to support access to public funding for SMEs and is consequently positive to all initiatives that support the development of SME markets. The SSDA see the suggested amendments as a step in the right direction but would also like to point out that further initiatives are most likely required to support SME markets. We note that this also seems to be the position of the EU Commission when stating that “any changes should therefore be understood as a first step in the right direction, and not as a single remedy in itself” and thereby look forward to any additional initiatives that would support SME listings. We would also like to stress that SME markets vary a lot across the EU and that they are to a large extent local by nature. Therefore, as we pointed out in our answer to the consultation leading to this proposal, it is difficult, if not impossible, to find a regulatory solution that is adapted to all SME markets in the EU. Hence, any regulatory framework needs to consider those differences and must be flexible. To consider those differences we advocated the need for outcome-based regulations where the areas to be regulated are decided at the EU level, but the actual rules are set in each jurisdiction or market-place. We are therefore very satisfied to notice that there is a certain room for flexibility in the proposed amendments.
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Response to EU small listed companies Act

19 Jun 2018

The SSDA welcomes the initiative to support access to public funding for SMEs and is consequently positive to all initiatives that support the development of SME markets. It is important to keep in mind that SME markets vary a lot across the EU and that they are to a large extent local by nature. Therefore, as we pointed out in our answer to the consultation leading to this proposal, it is difficult, if not impossible, to find a regulatory solution that is adapted to all SME markets in the EU. Hence, any regulatory framework needs to consider those differences and must be flexible. To consider those differences we advocated the need for outcome-based regulations where the areas to be regulated are decided at the EU level, but the actual rules are set in each jurisdiction or market-place. We are therefore very satisfied to notice that there is some room for flexibility in the proposed amendments.
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Meeting with Andrea Beltramello (Cabinet of Vice-President Valdis Dombrovskis)

28 Feb 2018 · SME listings

Response to Review of the European Supervisory Authorities

23 Jan 2018

Please see enclosed document
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Meeting with Lee Foulger (Cabinet of Vice-President Valdis Dombrovskis)

21 Jun 2016 · Capital Markets Union

Meeting with Lee Foulger (Cabinet of Vice-President Valdis Dombrovskis)

8 Dec 2015 · Capital Markets Union

Meeting with Jon Nyman (Cabinet of Vice-President Cecilia Malmström)

8 Dec 2015 · EU trade agenda, financial services in trade agreements, EU financial services regulation, Capital Markets Union