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The European Association of Corporate Treasurers

EACT

The EACT is a not-for-profit organisation bringing together as its members national treasury and finance professional associations (NTAs) in Europe.

Lobbying Activity

Response to Digital services for simplifying business operations and reducing administrative costs – the business wallet

12 Jun 2025

The European Association of Corporate Treasurers (EACT) welcomes the European Commissions initiative to establish a European Business Wallet (EBW) and fully supports its objectives. The initiative is a key step to enhance the efficiency and security of cross-border business operations within the EU internal market, as well as national business operations. As frequent users of financial and administrative services, our members regularly encounter the obstacles the EBW aims to tackle, namely fragmented identification frameworks, inefficient compliance processes, and divergent rules creating undue burdens for EU corporates. We therefore strongly support the establishment of a harmonised, interoperable, and legally recognised identity infrastructure for economic operators across the EU, serving as a primary method for identification, authentication, and data exchange in business-to-government (B2G), business-to-business (B2B), and government-to-government (G2G) digital interactions. Such simplification is particularly vital for SMEs that are often disproportionately affected by todays duplicative and costly procedures. In this context, we particularly perceive the potential of this initiative to pave the way for a more harmonised EU approach to Anti-Money Laundering (AML) / Know Your Customer (KYC) requirements. Today, corporates face a fragmented landscape in which onboarding with EU-regulated financial institutions often requires duplicating processes, documents, and verification methods across jurisdictions (and is some cases even across banks within the same country). The EBW, by enabling digital identification and secure data sharing, could offer a foundation for a future AML/KYC framework based on standardisation and mutual recognition. In more detail, as EACT we support the EBW as a potentially key enabler of: 1. A corporate AML passport a digital certificate issued after successful KYC with one EU financial institution, allowing other institutions to rely on it without repeating the onboarding process; 2. A single EU-wide core dataset and checklist for AML/KYC purposes and standardised evidence and verification protocols reducing administrative costs and onboarding delays; 3. The systematic use of the Legal Entity Identifier (LEI) as a pan-European standard for corporate identification. The EACT thus strongly supports the EBW initiative and encourages its rapid development and deployment, with a particular emphasis on its potential to serve as a foundation for more harmonised AML/KYC processes for corporates across the EU.
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Meeting with René Repasi (Member of the European Parliament, Rapporteur)

11 Jun 2025 · Payment Services Directive

Meeting with Maria Velentza (Director Competition) and

22 May 2025 · Exchange of views on EU payment markets

Response to Savings and Investments Union

4 Mar 2025

The European Association of Corporate Treasurers (EACT) welcomes the Commissions prioritisation of the Savings and Investments Union (SIU) project. As corporate treasurers using financial markets for our daily activities to support our businesses, we see four priority areas where the SIU can strengthen financing for companies and promote EUs strategic objectives: 1. Deepening short-term financing markets: commercial paper (CP) markets are a key source of short-term funding for companies, and EU-based CP market proves more expensive and less liquid their US counterparts. Fragmented issuance processes, and differing documentation standards may be driving these higher costs. We support an EU-level assessment of concrete measures to unify and deepen Europes CP markets, while preserving simplicity and ease of issuance for non-financial corporates. Money Market Funds (MMFs) also play a key role in liquidity management and short-term funding for corporates. Future MMF reforms should safeguard the diversity of fund types (including stable/low-volatility funds) so corporates can continue to invest and issue short-term debt cost-effectively. 2. Enhancing long-term financing options: easy and cost-efficient access to the most diverse range of long-term funding sources is a key concern for companies, especially in a climate of high rates and geopolitical uncertainty. Policy interventions should focus on initiatives to increase the scale and liquidity of EU capital markets (in order to attract both EU and non-EU investors), including creating ease of access and removing fundamental national bias and barriers. 3. Aligning sustainable finance with competitiveness: sustainable financing often remains more complex and costly than standard funding. For corporates, it is important that sustainable financing instruments (including green bonds) can be used to finance all business activities that are part of the transition to green as well as strategic sectors. 4. Ensuring efficient risk management and liquidity tools: access to efficient and diversified derivatives markets is crucial for corporate treasurers to hedge risks. It is thus important to preserve non-financial corporates (NFCs) EMIR current hedging exemption, to assess regulatory burdens for NFCs in the EMIR framework and ensure that EMIR implementation (including the active account requirements) does not undermine European financial institutions ability to provide efficient pricing for derivatives to EU corporates. Derivatives markets need to be considered by EU policy makers and authorities as integral to a capital market that delivers for EU companies, and we urge considerations on those markets to be prioritised in the upcoming CMU agenda. For example, it is surprising that the current Commission indicators for monitoring progress on CMU does not seem to consider derivatives markets, when they are an essential component of getting financing and good risk management for EU businesses.
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Meeting with Dirk Gotink (Member of the European Parliament)

4 Mar 2025 · Savings & Investments Union, payments

Meeting with Maria Luís Albuquerque (Commissioner) and

4 Mar 2025 · EACT representatives presented the association and its objectives.

Response to Single Market Strategy 2025

31 Jan 2025

The European Association of Corporate Treasurers (EACT) welcomes the Commissions initiative to address regulatory and administrative barriers to the Single Market. In our response, we want to bring out four concrete areas of measures which could contribute to simplifying the business environment and help stimulate investment and growth for companies in the EU economy. 1. ESG reporting needs standardisation and streamlining. While we value robust sustainability goals, overlapping rules (CSRD, Taxonomy, SFDR) and divergent national implementations escalate complexity and compliance costs. Moreover, reporting obligations for banks and investors cascade onto corporates, making access to finance harder and more costly. A holistic view of ESG requirements is thus essential to avoid unintended barriers to capital flows. Our suggestions include (1) establishing a EU sustainability reporting platform and reviewing CSRD definitions to ensure consistency with other laws (2) ensuring automatic interoperability with ISSB standards to prevent duplicated reporting (3) introducing a materiality principle in SFDR (making all PAI indicators subject to materiality test) to ensure that disclosure requirements are fit for purpose and consistent with CSRD (4) mapping existing climate/energy-related rules, including on climate transition plans (CSRD, ETS, IED, CS3D, CRD), with the aim of streamlining monitoring/audit obligations and avoid repetition of information. 2. Reporting requirements linked to the use of derivatives products by non-financial corporates should remain pragmatic and reasonable, balancing between the supervisory value of reporting and costs on corporates. An example of an overburdensome requirement, which brings no qualitative new information to supervisors, is the EMIR obligation on non-financial corporates to report their intra-group transactions. Whilst EMIR has added a possible exemption, the entire regulatory set-up (including the process to ask to benefit for the exemption) is burdensome for corporates using derivatives to hedge their business risks. It is also an example of a reporting requirement which has seen a lot of regulatory uncertainty: over the past 10 years, it has been reviewed 3 times without a proper impact assessment of the cost of the set-up in relation to the benefits for good information of the supervisors. 3. Divergent application of AML/KYC requirements across the EU creates substantial costs for corporates. More harmonisation and standardization in how KYC obligations are applied across member states would reduce administrative and compliance costs for EU businesses, without compromising the effectiveness of the AML framework. We would support the establishment of an EU AML passport for corporates, to facilitate new banks relationships once a KYC procedure with one bank has been completed, and/or a central KYC depository for banks and payment schemes to reduce the duplication of information. 4. EU corporates should benefit from a simple, internationally recognised way to identify themselves. We urge the EU to assess the adoption of an international standard, governed by regulators, as is the Legal Entity Identifier (LEI), for identification of EU businesses in the variety of cases when they need to prove their identity, including reporting, payments, ESG disclosures, AML, sanctions, procurement processes, and invoicing. Today corporates are faced with a myriad of options, often proprietary, national or lacking international recognition. EU business registers should be mandated to issue each legal entity in the EU an LEI in addition to a national identifier number, as a foundation for any upcoming reflections on a digital identity for businesses.
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Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

24 Sept 2024 · Capital markets and payments

Meeting with Markus Ferber (Member of the European Parliament)

24 Sept 2024 · Capital Markets Union / competitiveness

Meeting with Aura Salla (Member of the European Parliament)

24 Sept 2024 · Capital Markets Union

Meeting with Ondřej Kovařík (Member of the European Parliament, Rapporteur) and American Express Corporation

10 Oct 2023 · PSD III

Meeting with Dorien Rookmaker (Member of the European Parliament, Shadow rapporteur)

6 Jun 2023 · EMIR Review: Stakeholder consultation

Meeting with Dorien Rookmaker (Member of the European Parliament, Shadow rapporteur)

30 Mar 2023 · Stakeholder consultation on EMIR Review

Response to EMIR Targeted review

21 Mar 2023

Derivatives are essential instruments for companies of all sizes to manage uncertainties arising from their core business activities and connected financial fluctuations risks. European companies enter into derivative contracts as part of their financial risk management strategy to efficiently manage their risks linked to fluctuations in currencies, interest rates or commodities prices. The availability and efficiency of these instruments is even more important in the current context of high economic uncertainty that puts extensive constraints on European businesses and consumers alike. The EU framework has long recognised the specificities of non-financial counterparties (NFCs), and while the recent European Commission EMIR review proposal continues to largely recognise those, some of the proposed changes would have a detrimental impact on how NFCs use Over-The-Counter (OTC) derivatives. We understand some of those changes are driven by the energy crisis, but it is essential that the solutions designed to address the problems that have arisen in the energy derivatives markets are applied in a targeted manner. Disproportional mandatory central clearing, reporting and bilateral margining under EMIR would create extensive administrative burdens that will increase hedging costs and discourage corporates from using efficient risk management tools. Thus, in the context of the ongoing EMIR review: The regime for NFCs should stay largely untouched as it has proved effective for EU corporates. The current definition of hedging works well as it covers instruments legitimately used by corporates to mitigate risks associated with their commercial activities. Changes to the NFC reporting regime should be duly considered. In particular, removing the intragroup reporting exemption for NFCs would fail to address supervisory concerns linked to derivatives energy markets while creating important costs for small and medium sized companies. Some of the measures put forward by the Commission should be refined to better account for NFCs specificities. This includes the proposal to introduce a four-month implementation period for NFCs that become subject for the first time to the bilateral margining requirement for uncleared OTC derivatives. This implementation period should be extended give NFCs sufficient time put in place the necessary processes. About the European Association of Corporate Treasurers (EACT): Representing the European economy, the EACT brings together 14 000 corporate treasury professionals active in 22 countries and working for around 6 500 individual non-financial companies. Corporate treasurers are the finance professionals of the real economy.
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Meeting with Mairead McGuinness (Commissioner) and

16 Nov 2022 · Global economic situation Financial regulation and corporate risk management (EMIR, MiFID) Banking package ESG reporting Payments