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Swiss Finance Council

SFC

The Swiss Finance Council represents internationally active Swiss financial institutions and advocates their shared interests.

Lobbying Activity

Meeting with Nicolo Brignoli (Cabinet of Commissioner Valdis Dombrovskis)

15 Jul 2025 · ESRS

Meeting with Elena Arveras (Cabinet of Commissioner Maria Luís Albuquerque) and The Investment Association and

6 Jun 2025 · Sustainability Omnibus

Meeting with Didier Millerot (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

3 Jun 2025 · Discussion on sustainable finance developments in the EU and Switzerland's priorities

Swiss Finance Council urges interoperability in EU disclosure rules

30 May 2025
Topic — This consultation seeks to simplify EU rules on sustainable finance disclosures.
Message — The associations request that new rules be interoperable with international regulatory frameworks. They also urge removing entity-level reporting and providing an eighteen-month implementation period.123
Why — Simplified rules would lower the high compliance costs associated with reporting.45
Impact — Regulatory transparency regarding the total environmental impact of financial firms would decline.6
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Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

15 May 2025 · Global economic and financial outlook and EU developments

Meeting with Arba Kokalari (Member of the European Parliament)

7 May 2025 · Savings and Investments Union

Meeting with Stéphanie Yon-Courtin (Member of the European Parliament, Rapporteur)

13 Jan 2025 · Capital Markets Union / Retail Investment Strategy

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

30 Oct 2024 · • Future of CMU project and market access • Review of client categorisation framework to support the CMU • Basel III implementation in the EU, Switzerland and other jurisdictions

Meeting with Sofia Asteriadi (Cabinet of Vice-President Maroš Šefčovič)

7 Mar 2024 · Update on the EU-Switzerland relations

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

7 Mar 2024 · T+1 implementation, Basel III, EU Capital Markets Union

Meeting with Othmar Karas (Member of the European Parliament)

24 Nov 2023 · Kleinanlegerstrategie (RIS)

Meeting with Eero Heinäluoma (Member of the European Parliament, Shadow rapporteur) and Deutsche Börse AG

23 Oct 2023 · Retail investment strategy

Swiss Finance Council urges global alignment of sustainability standards

7 Jul 2023
Topic — The consultation defines the standards companies must use for mandatory sustainability reporting.
Message — They request better alignment with international standards to prevent double reporting for non-EU companies. They also propose transitional reporting timelines and clearer guidance on financial sector value chains.12
Why — This would lower expenses and simplify compliance for banks operating across multiple jurisdictions.3
Impact — Investors would lose data on banks' indirect environmental impacts under the proposed reporting limit.4
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Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur) and BUSINESSEUROPE and

8 Mar 2023 · Corporate Sustainability Due Diligence

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis) and UBS Group AG

25 Jan 2023 · Capital Requirements Regulation, Capital Requirements Directive, Retail Investment Strategy

Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur) and EUROPEAN TRADE UNION CONFEDERATION and

7 Nov 2022 · Corporate Sustainability Due Diligence

Meeting with Lukas Mandl (Member of the European Parliament)

12 Jul 2022 · AFET report on Switzerland / EU-Switzerland relations

Meeting with Mairead McGuinness (Commissioner) and

2 Mar 2022 · The latest regulatory and political developments in the European financial sector relevant to the SFC and its Members UBS and Credit Suisse

Meeting with Irene Tinagli (Member of the European Parliament, Committee chair)

2 Mar 2022 · Meeting on Banking Issues

Meeting with Maroš Šefčovič (Executive Vice-President)

2 Mar 2022 · EU-Swiss relations

Response to Commission Delegated Regulation on taxonomy-alignment of undertakings reporting non-financial information

2 Jun 2021

The Swiss Finance Council (SFC) welcomes the opportunity to provide feedback on the draft Delegated Act under Article 8 of the Taxonomy Regulation (hereafter the “DA”) and commends the European Commission’s active commitment to make the European Union climate-neutral by 2050. In this feedback, we would like to highlight the SFC’s key concerns identified in relation to the proposed DA. Our full comments have been uploaded alongside this feedback. Firstly, we would like to note that the phased implementation approach provided by the DA does not solve the significant challenge that financial institutions face in collecting EU Taxonomy data from their non-financial counterparts which are not subject to non-financial disclosure obligations themselves (i.e. not subject to the EU Non-Financial Reporting Directive – NFRD). The phased-in period, as currently designed by the Commission, equally applies to non-financial companies which are required to report complete KPIs only in 2023. To address this issue, we urge the Commission to establish a sensible sequence of disclosure requirements, whereby non-financial undertakings are required to disclose the complete KPIs one year earlier than financial institutions. Secondly, we are concerned about the draft DA’s approach to include exposures to market actors that are not covered by the NFRD (future CSRD), in particular SMEs and non-EU companies, in the denominator but not in the numerator of the KPIs for financial institutions. As noted by the EBA in its advice to the Commission, KPIs should be defined consistently, meaning that if certain activities are excluded from the numerator, they should be excluded also from the denominator. But the approach provided by the DA will lead to a lack of comparability between different institutions’ KPIs and the distortion will be particularly evident for financial institutions headquartered outside the EU due to the natural home bias that exists in their lending books. Therefore, we recommend including in both numerator and denominator only exposures to activities for which data can be sourced, i.e. only exposures to companies subject to the NFRD (future CSRD) obligations. Thirdly, we have concerns regarding the impact that the EU Taxonomy Article 8 reporting requirements may have on both financial sector and real economy companies in jurisdictions outside the EU, where the EU Taxonomy definitions are not legislated. In particular, financial institutions headquartered outside the EU that will fall within the scope of the future CSRD will be subject – unless clarified otherwise – to the disclosure obligations under the EU Taxonomy Regulation Article 8 for their entire portfolio. Moreover, non-EU financial institutions subject to the EU Taxonomy disclosure obligations will face significant challenges in collecting EU Taxonomy data from their clients/investees as a large part of non-EU companies will not have legal obligations to generate and disclose EU Taxonomy-relevant information. For these reasons, we reiterate our recommendation to include in both numerator and denominator only exposures to activities from which data can be sourced reliably, meaning only exposures to companies subject to the NFRD (future CSRD) obligations. This will not only ensure consistency and comparability of the KPIs as explained above, but would also limit unintended extra-territorial impacts of the EU Taxonomy Regulation. Lastly, we would like to point out that Annex V of the DA refers exclusively to IFRS’ accounting terminology, which could be problematic for non-EU financial institutions preparing financial statements according to the US GAAP (considered as equivalent to IFRS by the Commission). We would appreciate if the Commission could clarify that non-EU companies will be able to use US GAAP’s classifications as it would be disproportionate to require non-EU companies to prepare financial statements under EU IFRS for the purpose of this DA.
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Meeting with Gerassimos Thomas (Director-General Taxation and Customs Union)

24 Nov 2020 · Videoconference - Exchange on Suisse and EU tax priorities

Response to European Digital Identity (EUid)

3 Sept 2020

We welcome the intention of the European Commission to extend the use of digital or electronic identification (e-ID) to the private sector and to offer the possibility of private sector provision of digital identities within the framework of a revised Regulation on electronic identification and trust services for electronic transactions in the internal market (eIDAS Regulation). It is however important that the national e-ID systems should be made easily interoperable not only among EU member states but also with relevant third countries and non-EU financial centres. The EU should engage with other jurisdictions with a view to ultimately develop a broad-based global standard on interoperable and portable e-IDs based on agreed technical criteria. The Swiss Finance Council was established in 2013 to engage in dialogue around policy developments in finance at a European and international level. It represents the interests of internationally active Swiss financial institutions and provides a platform to share their experience, expertise and knowledge through a permanent representative office in Brussels. The current members of the Swiss Finance Council are Credit Suisse and UBS. The Swiss Finance Council supports an integrated Single Market that can contribute to the creation of a strong, open and globally competitive European financial sector, and it advocates for an EU that remains attractive to foreign investors and service providers.
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Response to Report on the application of the General Data Protection Regulation

29 Apr 2020

The Swiss Finance Council (SFC) would like to thank the European Commission for the opportunity to comment on the forthcoming report on the application of the EU General Data Protection Regulation (GDPR). In this respect, we would like to highlight a few aspects of particular relevance to our members by focusing our remarks on the merit of the Commission's review which is the issue of international transfer of personal data to third countries and the cooperation and consistency mechanism between national data protection authorities. You will find the SFC contribution enclosed.
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Meeting with Johannes Hahn (Commissioner)

4 Mar 2020 · To discuss the current state of play of EU-Switzerland relations

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis)

4 Feb 2020 · Digital finance

Meeting with Jérome Deslandes (Cabinet of Executive Vice-President Valdis Dombrovskis)

16 Dec 2019 · General discussion on Commission's priorities; Commission’s approach to third countries in Markets in Financial Instruments Directive and Capital requirements directive

Meeting with Stephen Quest (Director-General Taxation and Customs Union)

5 Dec 2019 · Update on international tax issues

Meeting with Andrea Beltramello (Cabinet of Vice-President Valdis Dombrovskis)

4 Jun 2019 · MiFID, PRIIPs, BASEL

Meeting with Roberto Viola (Director-General Communications Networks, Content and Technology)

27 Feb 2019 · Relations with 3rd countries for CONNECT issues incl. Cyber-resilience, DSM, Free flow of data, Blockchain

Meeting with Johannes Hahn (Commissioner) and

27 Feb 2019 · EU Swiss relations

Meeting with Olivier Guersent (Director-General Financial Stability, Financial Services and Capital Markets Union)

24 May 2018 · MiFIR, EMIR, AIFMD

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

15 May 2018 · Third country aspects of current financial services legislation

Meeting with Stephen Quest (Director-General Taxation and Customs Union)

25 Apr 2018 · Exchange of views on EU tax priorities

Meeting with Olivier Guersent (Director-General Financial Stability, Financial Services and Capital Markets Union)

28 Feb 2018 · EU-Swiss relations

Meeting with Elina Melngaile (Cabinet of Vice-President Valdis Dombrovskis)

7 Jun 2017 · the EU sustainable finance strategy in the wider context of the Capital Markets Union

Meeting with Aare Järvan (Cabinet of Vice-President Andrus Ansip)

28 Mar 2017 · EU Digital Single Market and Digital Banking

Meeting with Stephen Quest (Director-General Taxation and Customs Union)

30 May 2016 · Exchange of views on tax issues

Meeting with Denzil Davidson (Cabinet of Commissioner Jonathan Hill)

24 May 2016 · Retail Financial Services and Digitalisation

Meeting with Chantal Hughes (Cabinet of Commissioner Jonathan Hill)

12 Apr 2016 · Overview Financial Services

Meeting with Jonathan Hill (Commissioner)

17 Feb 2016 · Capital Markets Union

Meeting with Nathalie De Basaldua Lemarchand (Cabinet of Commissioner Jonathan Hill)

20 Jan 2016 · Preparation of the Meeting with the Commissioner.

Meeting with Edward Bannerman (Cabinet of Vice-President Jyrki Katainen)

26 Mar 2015 · Investment plan

Meeting with Chantal Hughes (Cabinet of Commissioner Jonathan Hill)

5 Mar 2015 · Banking

Meeting with Heinz Zourek (Director-General Taxation and Customs Union) and Credit Suisse Group AG

23 Feb 2015 · Current Taxation issues and EU-Swiss dossiers

Meeting with Matthew Baldwin (Cabinet of Commissioner Jonathan Hill)

23 Feb 2015 · Financial Policy

Meeting with Heinz Zourek (Director-General Taxation and Customs Union)

4 Dec 2014 · BEPS, FTT, FATCA, EUSD/DAC and consequences for 3rd countries