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Vanguard Asset Management Limited

Vanguard Asset Management Limited is one of the world's leading investment management companies.

Lobbying Activity

Meeting with Helene Bussieres (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

18 Dec 2025 · SFDR, market integration package

Meeting with Emiliano Tornese (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

6 Nov 2025 · Exchange of views on macroprudential policies for NBFI, focusing on asset management.

Meeting with Emiliano Tornese (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

19 Jun 2025 · Exchange of views on the macro-prudential approach for non-bank financial intermediation and potential stress tests

Meeting with Tatyana Panova (Head of Unit Financial Stability, Financial Services and Capital Markets Union) and BlackRock and

2 Jun 2025 · Exchange with asset managers on the integration of EU capital market

Vanguard Urges Inclusive and Simplified EU Sustainable Finance Rules

30 May 2025
Topic — The Commission is reviewing rules for disclosing information on sustainable finance products.
Message — Vanguard supports a categorization framework including existing strategies and exclusionary index funds. They request the elimination of duplicative reporting by consolidating entity-level disclosures.12
Why — Harmonized rules would allow the firm to offer scalable products and reduce compliance costs.3
Impact — Retail investors lose out if restrictive labeling limits access to diversified investment options.4
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Meeting with Nicolo Brignoli (Cabinet of Commissioner Valdis Dombrovskis)

6 May 2025 · Omnibus

Response to Savings and Investments Union

7 Mar 2025

Vanguard strongly supports the Savings and Investments Union (SIU) initiative as a means to strengthen the EU economy, capital markets and enhance long-term savings opportunities for citizens. A well-functioning SIU is both an economic necessity and a political and strategic imperative in an era of heightened global competition and demographic shifts. By fostering deeper and more efficient capital markets, the SIU can mobilize private investment to support Europes transition to a more secure, sustainable and digital economy and society. To help inform the strategy for SIU, Vanguard has sponsored research by the thinktank New Financial, Analysis of retirement saving and retail investing in the EU and recommendations for an integrated reform agenda (available here: https://www.ie.vanguard/content/dam/intl/europe/documents/en/the-future-of-pensions-and-retail-investments.pdf). New Financial estimates that an ambitious, integrated policy agenda could unlock an additional 11 trillion in pension and retail investment in the EU. If one-third of this additional investment was channelled into European assets (in line with the average asset allocation of UCITS equity funds), this would give the European economy a significant boost. Based on this research and Vanguards five decades of serving retail investors across international markets, we see three essential priorities for the success of SIU and the financial wellbeing of EU citizens: (1) widespread adoption of European savings accounts; (2) development of funded pension systems; and (3) open and competitive retail investment markets. 1. Widespread adoption of European savings accounts The EU should prioritize the creation of flexible, tax-incentivized savings vehicles across the EU27, potentially modelled on Swedens ISK or the UKs ISA. This initiative would complement existing pension products by offering savers a liquid and accessible option for both short- and long-term financial goals, without the rigid constraints of traditional retirement schemes. As acknowledged by the call for evidence, the future SIU should help citizens get higher returns on their savings, also serving their retirement needs. On specific design principles for European savings accounts we would endorse the contribution by ICI Global to this call for evidence. 2. Development of funded pension systems across the Member States Strengthening retirement saving for citizens must complement work on savings accounts. With demographic shifts placing greater pressure on public budgets, it is essential to enhance the availability, accessibility, and attractiveness of funded pension systems across the EU. Decisions on the design of national pension systems across all three pillars (state, occupational and personal) belong to the Member States. However there is merit in the Commission working to build consensus among the Member States on good system design and effective measures to channel long-term investment into the EU economy. Alongside the obvious emphasis on private pensions, we note the role that funded pillar 1 schemes play in anchoring the growth of domestic capital markets (e.g. in Sweden, Denmark and Japan). 3. Open and competitive retail investment markets To truly benefit citizens, the SIU must develop retail distribution systems that empower individuals to participate more actively in EU capital markets. This requires a broad and long-term vision: one that moves beyond the current confines of the Retail Investment Strategy debate towards a constructive partnership between the Commission, Member States and the Parliament. Retail investor protection should take a holistic approach, enabling EU savers to achieve better financial outcomes by taking measured risk in an informed and responsible way. The keys to this effort include: better calibrated options for advice and guidance; targeted education at key stages in the investor journey; lighter and more proportionate product disclosure; and
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Meeting with Elena Arveras (Cabinet of Commissioner Maria Luís Albuquerque), Philippe Thill (Cabinet of Commissioner Maria Luís Albuquerque)

28 Feb 2025 · The Savings and Investments Union (SIU)

Meeting with Tilman Lueder (Head of Unit Financial Stability, Financial Services and Capital Markets Union) and Fleishman-Hillard and

20 Feb 2025 · CMU discussion with asset management industry

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

21 Nov 2024 · Retail investment policy

Meeting with Agnieszka Drzewoska (Cabinet of Commissioner Mairead Mcguinness)

23 Nov 2023 · Retail investment strategy

Meeting with Eero Heinäluoma (Member of the European Parliament, Shadow rapporteur)

24 Oct 2023 · Retail investment strategy

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

11 Apr 2023 · Retail Investment Strategy

Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur) and BlackRock and

15 Mar 2023 · Corporate Sustainability Due Diligence

Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur) and BUSINESSEUROPE and

8 Mar 2023 · Corporate Sustainability Due Diligence

Meeting with Simon Genevaz (Cabinet of Executive Vice-President Margrethe Vestager)

27 Feb 2023 · Retail Investment Strategy

Meeting with Agnieszka Drzewoska (Cabinet of Commissioner Mairead Mcguinness) and FTI Consulting Belgium

24 Nov 2022 · Retail Investment Strategy

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

24 Nov 2022 · Retail investment strategy

Meeting with Valeria Miceli (Cabinet of President Ursula von der Leyen)

21 Nov 2022 · Retail investment strategy

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness)

21 Apr 2022 · MiFID II Retail Investment Strategy

Meeting with Danuta Maria Hübner (Member of the European Parliament, Rapporteur) and BlackRock and

9 Mar 2022 · MiFIR Review and CMU Package

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

15 Dec 2021 · Sustainable economy, ESG

Meeting with Agnieszka Drzewoska (Cabinet of Commissioner Mairead Mcguinness), Claude Bocqueraz (Cabinet of Commissioner Mairead Mcguinness) and

26 May 2021 · Retail investment

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness)

15 Jan 2021 · CMU/retail investment

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

17 Apr 2020 · The role of Capital markets in the economic recovery from COVID-19

Meeting with Andrea Beltramello (Cabinet of Vice-President Valdis Dombrovskis) and FTI Consulting Belgium

13 May 2019 · Capital Markets Union

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

14 May 2018 · PEPP - Cross-border distribution of investment products

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

6 Mar 2018 · Sustainable Finance & fiduciary duty

Response to Review of the appropriate prudential treatment for investment firms

19 Apr 2017

Vanguard Asset Management, Limited (VAM) welcomes the opportunity to provide feedback on the review of the appropriate prudential treatment for investment firms (the Review"). Further details of how VAM, and the broader Vanguard group, operates, is set out in the position statement provided in conjunction with this feedback (the Position Statement). As further detailed within our Position Statement, we do not believe that the existing regime under the EU Capital Requirements Directive and Regulation (CRD/CRR"), as it applies to investment firms, is appropriate. In particular, CRD/CRR was fundamentally designed to mitigate the systemic risks arising from banking business and does not reflect the business models and capture the risks posed by different types of investment firms in a suitable or proportionate manner. For example, asset managers such as VAM do not engage in activities that would pose systemic risk for the reasons outlined below and therefore should not be subject to the same capital requirements as those entities that do (including other investment firms): (a) Asset managers tend to have small balance sheets and employ little to no leverage. There is little evidence of investors redeeming from funds to an extent that would create a significant market impact. An asset manager is therefore very unlikely to fail in a way that would require regulatory intervention or that causes a systemic risk to financial stability. (b) Asset managers act as agents on behalf of their clients and do not use their balance sheets in transactions between their clients and the market. Furthermore, client assets are typically segregated and held by a third party for the benefit of the clients. (c) As a result of the comprehensive regulation to which asset managers are subject, they do not engage in the type of activities which cause systemic risk. In particular, asset managers must comply with detailed and far reaching conduct of business rules set out in legislation such as the Markets in Financial Instruments Directive; the Market Abuse Directive; UCITS Directive and the Alternative Investment Fund Managers Directive. As set out above, the activities undertaken by firms such as asset managers do not present the same risks as credit institutions or other investment firms. This divergence between firms is not reflected in prudential treatment under CRD / CRR and therefore capital requirements are applied disproportionately. This leads to a complex and unsuitable regime, compliance with which is a significant burden upon firms. We support the objective of the Review of achieving a more appropriate and proportionate regime by amending the existing EU legal framework: however, in order to ensure an effective regime we believe creating a new stand-alone measure would be the most appropriate approach. In taking this approach, it is important that any separate regime is tailored for, and proportionate to, the risks associated with investment firms and also the differences between firms. There would have to be clear guidelines surrounding this, which would need to take into account several factors, including those outlined below: (a) The size of an investment firm is not an accurate indication of the level of systemic risk presented by that firm. There are large firms who undertake activities which do not present as much risk to customers as those carried out by smaller firms. (b) Systemic risk emanates from the combination of leverage and interconnectedness and this should be a key determinant of any risk calculation under a new stand-alone regime. (c) Risk metrics based on the holding of client money / assets should be proportionate. Asset managers use an agency model and client assets are typically segregated. Therefore, any revised prudential regime for asset managers should only require firms to hold sufficient capital to allow them to wind down in an orderly manner when necessary.
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Meeting with Paulina Dejmek Hack (Cabinet of President Jean-Claude Juncker)

3 Jun 2016 · EU pensions landscape

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

3 Jun 2016 · EU pensions; Capital Markets Union Action Plan

Meeting with Marlene Madsen (Cabinet of Vice-President Jyrki Katainen)

3 Jun 2016 · EU pensions

Meeting with Ioana Diaconescu (Cabinet of Commissioner Pierre Moscovici)

2 Jun 2016 · EU pensions system

Meeting with Matthew Baldwin (Cabinet of Commissioner Jonathan Hill)

15 Sept 2015 · Financial issues

Meeting with Valérie Herzberg (Cabinet of Vice-President Jyrki Katainen)

15 Sept 2015 · Capital markets union + personal pensions initiative