Competitiveness in the single banking market

51 submissions in the snapshot (39 from organisations), portal total 51. Feedback list on the portal.

39 of 39 organisation submissions analysed; the model reads them as: opposes 2 supports 1 wants changes 30 6 held back for review (low confidence).

• Reclaim Finance NGO, FRA; register: Non-governmental organisations, platforms and networks and similar model reads as: opposes source
  • Reject calls to lower regulatory requirements on the banking sector.

    Reclaim Finance warns the Commission against calls to lower the regulatory requirements on the banking sector.

  • Preserve the current prudential framework and especially protect all climate-related provisions.

    Reclaim Finance urges the Commission to preserve the current prudential framework, and especially to protect all climate-related provisions.

  • Any simplification should not affect capital levels or banks' ability to face current and emerging threats.

    The NGO underlines that a limited simplification is possible - for example building on the proposal of the European Central Bank - but should not affect capital levels and bank's ability to face current as well as emerging threats.

• French Banking Federation Business association, FRA model reads as: wants changes source
  • Stabilize and freeze the output floor at its current level with permanent treatment for low-risk mortgages, unrated corporates, and client hedging.

    The EU should quickly adopt measures that unlock tangible credit capacity, notably by stabilising the output floor arrangements through a permanent treatment for low risk mortgages, unrated corporates and client hedging, and by freezing the output floor at its current level.

  • Immediately remove the CET1 software deduction as digital investment is crucial for resilience and competitiveness.

    The immediate removal of the CET1 software deduction is equally necessary, as digital investment is crucial for resilience and competitiveness.

  • Introduce a competitiveness tool in Level 1 legislation so that growth and competitiveness become explicit secondary objectives of regulation and supervision.

    Introducing a competitiveness tool in Level 1 legislation is needed so that growth and competitiveness become explicit secondary objectives of regulation and supervision.

• Zentralverband des Deutschen Handwerks e.V. Business association, DEU; register: Trade and business associations model reads as: supports source
  • Simplify banking regulation to facilitate lending to businesses.

    simplification of banking regulation, which could facilitate lending

    machine translation by the Commission, original in DE
  • Implement proportionate regulatory requirements for small banks and small business lending.

    proportionate requirements are needed for small banks as well as for lending to small businesses

    machine translation by the Commission, original in DE
• Verband deutscher Pfandbriefbanken Business association, DEU; register: Trade and business associations model reads as: wants changes source
  • Cap the output floor at 50% of the standardised approach to better support lending capacity, competitiveness and housing affordability.

    a more proportionate and permanent calibration, such as capping the output floor at 50% of the standardised approach, would better support lending capacity, competitiveness and housing affordability.

  • Recognize and emphasize the effectiveness and targeted nature of state guarantees as a risk-reduction instrument to mitigate capital requirement disproportions.

    To mitigate these disproportionate effects, the vdp emphasises the effectiveness and targeted nature of state guarantees as a risk-reduction instrument.

  • Implement swift legislative changes to address the imminent rise in capital requirements and ensure planning certainty for long-term real estate lending.

    Swift legislative changes, in phased steps if needed, should address the imminent rise in capital requirements first to ensure planning certainty for long-term real estate lending.

• Finance Denmark Business association, DNK; register: Trade and business associations model reads as: wants changes source
  • The EU should recalibrate its Basel 3.1 implementation to prevent the Output Floor from becoming a binding capital requirement for European IRB banks.

    the EU should recalibrate its Basel 3.1 implementation

  • Establish a simpler, more harmonized and consistently applied macroprudential regime with restricted national discretion.

    A simpler, more harmonized and consistently applied macroprudential regime is essential to restore a level playing field.

  • Avoid introducing new sector-specific bank taxation.

    avoid new sector-specific taxation

• Finance Sweden Business association, SWE; register: Trade and business associations model reads as: wants changes source
  • Remove the Systemic Risk Buffer Requirement (SyRB) and eliminate overlapping capital buffer requirements to align the European framework with Basel standards.

    Remove the Systemic Risk Buffer Requirement (SyRB) to make the European framework Basel aligned and avoid duplicative capital requirements.

  • Make the CRR3 transitional arrangements on unrated corporates and mortgage credit permanent at the current level to prevent increased financing costs.

    Making the CRR3 transitional arrangements on unrated corporates and mortgage credit permanent at the current level would ensure that EU economies are not met with increasing financing costs, thus preserving EU competitiveness.

  • Reject the AMLA draft RTS Article 17 look-through requirements for collective investment undertakings as duplicative and operationally unfeasible.

    The application of Article 17 appears to result in a duplication of CDD, without any corresponding additional risk mitigation.

• EMF-ECBC Business association, BEL model reads as: wants changes source
  • Fix the Output Floor at its current level to enhance EU bank competitiveness and support affordable housing.

    Fixing the OF at its current level would enhance the competitiveness of EU banks internationally, ensure a strategic level playing field with jurisdictions that employ an off-balance-sheet approach to mortgages, and reinforce banks ability to support affordable and sustainable housing.

  • Reassess the introduction of the Prudent Value in capital requirements, replacing the established market value and mortgage lending value concepts.

    This context also underlines the need to reassess the introduction of the PV in Art. 229 CRR as a new valuation concept in place of the well-established concepts of MV and MLV.

  • Establish a European mortgage guarantee scheme as a 28th regime to enable banks to expand lending to targeted social segments.

    Finally, we wish to highlight the value of a European mortgage guarantee scheme as a 28th regime, complementing well-functioning national systems and playing a key role in enabling banks to expand lending to targeted social segments while enhancing housing affordability and sustainability, and data quality.

• Sustainable Finance Lab NGO, NLD model reads as: wants changes source
  • Redefine banking sector competitiveness to prioritize shock absorption and financing households and businesses over profitability and market share metrics.

    A competitive EU banking sector should be defined by its ability to absorb shocks while continuing to finance households and businesses, as much as it should be defined by profitability or market share.

  • Strengthen prudential frameworks to better integrate borderless risks like climate change into financial risk models and banking stress testing.

    If these risks are not fully integrated into financial risk management, banks may appear profitable and stable in the short term while vulnerabilities accumulate over time.

  • Adopt supervisory approaches that address system-wide interconnectedness risks arising from common ownership and shared exposures, not just individual institution risks.

    Strengthening the resilience and competitiveness of the EUs banking sector therefore requires a supervisory perspective that better reflects the interconnected nature of the financial system.

• Confederation of Swedish Enterprise Business association, SWE; register: Trade and business associations model reads as: wants changes source
  • Quantify the impact on unrated corporate lending, pricing, volumes and maturities to identify disproportionate effects across Member States.

    We therefore urge the Commission to quantify the impact on unrated corporate lending (pricing, volumes and maturities) and consider permanent, risk-sensitive adjustments where disproportionate effects are identified.

  • Maintain the transitional preferential treatment for unrated corporates until such quantification and assessment is completed.

    Until then, the transitional preferential treatment for unrated corporates should be maintained.

  • Recalibrate the output floor to account for banking systems with historically low losses and ensure neutrality across Member States.

    The output floor is a clear example: at the current calibration it can impose disproportionate costs on bank-based corporate finance in banking systems with historically low losses, distorting the level playing field within the Single Market.

• Association française des sociétés financières Business association, FRA; register: Trade unions and professional associations model reads as: wants changes source
  • Reconsider leasing prudential constraints in light of EBA analysis and the Commission's competitiveness action plan.

    It is essential to reconsider leasing prudential constraints against the background of the upcoming report and action plan from the European Commission to enhance competitiveness in the single banking market.

  • Introduce more favorable prudential treatment for factoring in the Standardized Approach for credit risk to reflect its low risk profile.

    It is time to introduce a more favourable prudential treatment for factoring in CRR in the Standardized approach for credit risk (SA-CR) better reflecting its low risk profile.

  • Implement adapted prudential rules that reflect the lower risk profile of asset-backed financing solutions such as leasing and factoring.

    Regulatory stability, visibility and clarity are required to unlock the potential of specialized financing in order to finance European competitiveness, along with adapted prudential rules that really reflect the lower risk profile of asset backed financing solutions such as leasing and factoring.

• The European Association of Corporate Treasurers Business association, FRA; register: Trade unions and professional associations model reads as: wants changes source
  • Make permanent the more proportionate capital treatment for hedging derivatives after 2029 to keep hedging accessible and affordable for European corporates.

    We support making permanent the current, more proportionate capital treatment for hedging derivatives after 2029, so that economically sound hedging remains accessible and affordable for European corporates.

  • Make permanent the 65% risk weight for unrated corporates instead of allowing it to revert to 100% from 2032 onwards.

    We ask the 65% risk weight for unrated corporates be made permanent.

  • Ensure that prudential policy supports competitiveness and development of deep, resilient capital markets offering corporates effective choice of financing partners.

    we are keen to ensure that prudential policy is calibrated so as to support the competitiveness of the EU economy and of its corporates, and the development of deep, resilient capital markets that offer corporates an effective choice of partners.

• Victoria Unmveristy wellington Academic or research institution, NLD model reads as: wants changes source
  • Complete the Banking Union by unifying supervisory powers and delivering a credible EDIS as the highest-impact structural reform.

    First, structural integration: completing the Banking Union (unifying supervisory powers and delivering a credible EDIS) is the single highest-impact reform available.

  • Review and recalibrate the cumulative complexity of financial regulations including FRTB calibration, K-factor cliff effects, and MiFID II advice requirements.

    Second, proportionality and recalibration: the cumulative interaction of CRR/CRD, MiFID II, EMIR, CSDR, AIFMD, and macroprudential frameworks creates complexity disproportionate to the risks mitigated. Specific areas warranting review include FRTB calibration for market makers in less liquid EU instruments, K-factor cliff effects in IFR/IFD, and MiFID II advice requirements that contribute to a retail investment gap.

  • Develop capital market depth through EU securitisation revival, PEMO status implementation, equity consolidated tape, and funded pension systems.

    Third, capital market depth: reviving EU securitisation (currently 1% of GDP versus 6% in the US), implementing PEMO status and the equity consolidated tape under the December 2025 Market Infrastructure Package, and developing funded pension systems to build the long-term institutional investor base that capital markets require on the demand side.

• L'AFEP Business association, FRA; register: Trade and business associations model reads as: wants changes source
  • Perform a holistic review of capital requirements to address the constant increase due to supervisory practices.

    perform a holistic review of capital requirements including the constant increase due to supervisory and European agencies practices and guidance

  • Freeze the output floor at its current level to ensure adequate lending capacity.

    freeze the output floor at its current level

  • Introduce a competitiveness tool in Level1 legislation to ensure EU competitiveness and growth are considered alongside financial stability.

    introduce a competitiveness tool in Level1 legislation, to ensure that the EU political objectives of competitiveness and growth are considered in regulatory and supervisory policies as complementary to financial stability goals

• Micro company, BEL Business association, BEL model reads as: wants changes source
  • Remove contractual bans on assignment of receivables in Member States to facilitate cross-border factoring transactions.

    Removing these clauses would simplify cross border transactions, reinforce competition, and foster innovation in digital receivables ecosystems, fully aligned with the EUs agenda on competitiveness and simplification.

  • Reform the prudential framework to apply more risk-sensitive capital calibration to short-term purchased receivables.

    A more risk sensitive calibration, such as discounted risk weights for non recourse purchased receivables with maturities up to 90 days, and a substitution approach for recourse transactions where operational control of cash flows is strong, would reduce unnecessary capital absorption while maintaining supervisory soundness.

  • Align Eurostat statistical treatment to recognize non-recourse factoring as distinct from borrowing for government sector debtors.

    Aligning statistical treatment with economic substance, recognizing true sale, non recourse factoring as distinct from borrowing, would reinforce timely payment objectives without compromising fiscal transparency.

• WWF EPO NGO, BEL; register: Non-governmental organisations, platforms and networks and similar model reads as: opposes source
  • Reframe banking policy objectives away from bank competitiveness alone toward supporting a productive and competitive economy.

    the objective of banking policy should not be competitiveness of banks alone, but a banking system that supports a productive and competitive economy.

  • Revisit credit policies to support financing for European priority sectors aligned with EU sustainability goals.

    It also calls for revisiting credit policies to support financing for European priority sectors aligned with EU sustainability goals, to strengthen competitive sustainability and strategic autonomy.

  • Maintain strong capital and supervisory frameworks as essential safeguards rather than weakening them.

    weakening prudential safeguards would be ill-timed: strong capital and supervisory frameworks help shield the banking sector from external shocks and support the economy during periods of instability.

• Unipol Assicurazioni S.p.A. Company, ITA; register: Companies & groups model reads as: wants changes source
  • Extend the competitiveness initiative to the financial sector as a whole, not just banking.

    We would further urge the Commission to extend this initiative to the financial sector as a whole.

  • Harmonize FICOD and Solvency II regimes by introducing a prudential mechanism similar to the Danish Compromise for insurance-led conglomerates.

    we call upon the Commission to harmonize the FICOD and Solvency II regimes by introducing a prudential mechanism similar to the 'Danish Compromise' for insurance-led conglomerates.

  • Ensure a level playing field across legislative frameworks governing different segments of the financial sector.

    one essential starting point is to ensure a level playing field across the legislative frameworks governing the different segments of the financial sector.

• European Association of Public Banks Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Remove the requirement for prior supervisory approval when promotional and public banks assign instruments to the banking book.

    The framework should therefore avoid requiring prior supervisory approval for such assignments.

  • Reform the automatic classification of client-related derivatives as trading book positions to reduce operational burden for institutions without trading activities.

    The automatic classification of client-related derivatives as trading book positions creates operational burden and higher capital requirements for institutions that do not engage in trading or market-making activities.

  • Apply proportionate stress-testing frameworks that account for the public mandate, low-risk profile and absence of complex trading activities of promotional and public banks.

    A more proportionate approach, taking into account the public mandate, low-risk profile and absence of complex trading activities, would be more appropriate.

• Finance Watch NGO, BEL; register: Non-governmental organisations, platforms and networks and similar model reads as: wants changes source
  • Establish a mechanism with monitoring linking the outcome of future reforms to the objective of improving conditions for banks, investors, consumers, firms and strategically relevant European projects seeking financing.

    Furthermore, from the public policy perspective, any rationalisation measures proposed should establish a mechanism, including monitoring, linking the outcome of any future reforms to the objective stated in the Call for Evidence - improving the conditions for banks, investors, consumers, firms and strategically relevant European projects seeking financing, and ultimately the EU economy.

  • Implement specific measures including phasing out the regulatory use of IRB modelling, raising leverage ratios, simplifying elements of the capital stack, and promoting diversity of banking business models by helping small, local, community, and public banks.

    Measures that we believe could help achieve these objectives include: Phase out the regulatory use of IRB modelling Raise leverage ratios Simplify some elements of the capital stack Promote diversity of banking business models by helping small, local, community, and public banks.

  • Ensure that the overall capital strength of EU banks increases or at least does not reduce over the period in which simplification measures are implemented, using baseline measurement now and comparative monitoring in the future.

    The Commission should ensure that the overall capital strength of EU banks increases or at least does not reduce - over the period in which simplification measures are implemented, by taking a baseline measure of capital strength now and setting dates for comparative monitoring in the future.

• Raisin SE Company, DEU model reads as: wants changes source
  • Implement harmonization initiatives addressing the distribution of banks' products to ensure regulatory coherence and proportionality.

    In this context, we believe that any harmonization initiatives that address the distribution of banks' products (e.g., deposits) are important to ensure that the regulatory framework remains coherent, effective, and proportionate.

  • Replace isolated national approaches with coordinated EU action to ensure consistent implementation of common rules across the Single Banking Market.

    The Commission should seek to replace isolated national approaches with coordinated EU action that ensures consistent implementation of common rules, thereby fostering a more integrated, efficient, and competitive Single Banking Market.

  • Address barriers and national discretions in regulatory implementations that prevent banks from operating seamlessly across borders.

    Sizeable barriers continue to prevent banks from operating seamlessly across borders, often stemming from national discretions and divergent implementations of common rules.

• Bank of Valletta Company, MLT model reads as: wants changes source
  • Make proportionality and simplified reporting and disclosure for non-systemic institutions a core design principle of SIU reforms.

    Meaningful proportionality, including simplified reporting and disclosure for nonsystemic institutions, should therefore be a core design principle of SIU reforms.

  • Establish a more coherent and proportionate supervisory environment with enhanced cross-border cooperation and streamlined crisis management frameworks.

    A more coherent and proportionate supervisory environment, supported by enhanced cross border cooperation and streamlined crisis management frameworks, is therefore critical to deepening the Single Market.

  • Address scale asymmetries in securitisation frameworks to prevent reinforcing competitive divergence between large pan-European banks and domestically focused institutions.

    Without addressing scale asymmetries, securitisation risks reinforcing competitive divergence between large panEuropean banks and domestically focused institutions.

• Febelfin Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Shift regulatory focus from adding new rules to optimizing and reducing existing ones.

    The EU should shift focus from adding new rules to optimizing, and where appropriate, reducing existing ones.

  • Implement a comprehensive Financial Omnibus to address fragmentation and complexity in financial sector regulation and policymaking procedures.

    a comprehensive Financial Omnibus, taking a holistic view of both the regulatory framework for the financial sector and the procedural aspects of financial policymaking, could be of significant value.

  • Ensure swift implementation of proposals rather than treating them as a long-term exercise.

    Given the scale of the work, it is essential that these proposals would not be part of a long-term exercise but would come swiftly.

• Fédération Européenne de Finances et Banques Ethiques et Alternatives Business association, BEL model reads as: wants changes source
  • Regulatory policy should prioritize ensuring banks channel credit to the real economy rather than treating bank profitability as a policy objective.

    Regulatory policy should therefore prioritise ensuring that banks can effectively channel credit to households, businesses and strategic investments rather than treating bank profitability as a policy objective in itself.

  • Focus regulatory simplification on improving clarity, efficiency and proportionality of existing rules while maintaining prudential safeguards.

    Regulatory simplification should therefore focus on improving the clarity, efficiency and proportionality of existing rules rather than weakening prudential safeguards.

  • Implement targeted proportionality measures and improved supervisory coordination to reduce disproportionate regulatory and reporting burdens on smaller and non-complex banks.

    In particular, the regulatory and reporting burden is disproportionate for smaller and non-complex banks. Targeted proportionality measures and improved supervisory coordination could enhance regulatory effectiveness while preserving financial stability and maintaining the EUs climate risk framework.

• Build Europe Business association, BEL model reads as: wants changes source
  • Conduct a technical review of the current prudential framework to better reflect the diversity of residential development models and the risk profile of pre-sold and well-capitalized projects.

    Build Europe calls for a technical review of the current framework to ensure that it better reflects the diversity of residential development models across Europe and the specific risk profile of pre-sold and well-capitalised projects.

  • Assess whether the eligibility criteria for the 100% risk weight under Article 126a adequately reflect market practices and whether evidence on default rates could justify more risk-sensitive treatment for low-risk residential development exposures.

    In particular, the review should assess whether the eligibility criteria for the 100% risk weight under Article 126a adequately reflect market practices, whether the broader prudential framework may have unintended consequences for housing financing, and whether supervisory guidance could improve consistency across Member States. It should also consider whether evidence on default rates and long-term housing market stability could justify more risk-sensitive treatment for certain low-risk residential development exposures.

  • Review the interaction between prudential requirements and national consumer protection frameworks governing off-plan residential sales to prevent unintended constraints on low-risk projects.

    Build Europe also highlights the interaction between prudential requirements and national consumer protection frameworks governing off-plan residential sales. In several Member States, consumer protection legislation limits the level of advance payments that developers may request from buyers or requires payments to follow construction progress. These legal constraints may prevent otherwise low-risk projects from meeting certain prudential thresholds, even when substantial risk-mitigating elements are present.

• German Savings Banks Association (DSGV) Business association, DEU; register: Trade and business associations model reads as: wants changes source
  • Competitiveness should become an explicit objective in the mandates of European Supervisory Authorities, AMLA and the SSM, guiding rulemaking as an operational principle.

    Competitiveness should become an explicit objective in the mandates of the European Supervisory Authorities, AMLA and the SSM, acting as an operational principle for rulemaking rather than an abstract aspiration.

  • Well-functioning institutional protection schemes must be preserved as they are essential for financial stability, depositor confidence, and banking diversity.

    Well-functioning institutional protection schemes (IPS) must be preserved, as they are essential for financial stability, depositor confidence, and banking diversity in Europe.

  • The EU capital framework should be simplified and made more coherent by consolidating buffer requirements and removing unnecessary requirements like the Systemic Risk Buffer.

    The EU capital framework should be simplified and made more coherent, for instance by consolidating buffer requirements and removing unnecessary goldplating like the Systemic Risk Buffer.

• Transnational Institute Academic or research institution, NLD model reads as: wants changes source
  • Do not base the EC competitiveness report on comparisons with US listed banks, as they operate under different regulatory frameworks and macro-prudential conditions.

    The ECs report on competitiveness of EU banks should not be about comparing EU banks with US listed banks.

  • Implement higher capital requirements to ensure the EU banking sector can finance climate-related and strategic transformation of the EU economy.

    In order to keep the EU banking sector resilient and capable of financing the climate related and strategic transformation of the EU economy to the benefit of its citizens, higher capital requirements should be considered.

  • Ensure any changes to bank laws include concrete measures to increase lending to EU priority sectors and prevent increased shareholder payouts.

    Any potential changes in bank laws should integrate concrete measures that result in banks higher risk appetite for lending to EU priority sectors and policy objectives, and should prevent boosting pay-outs to shareholders.

• Polish Bank Association Business association, POL; register: Trade and business associations model reads as: wants changes source
  • Apply the principle of proportionality so that smaller, stable banking institutions are not subject to the same regulatory obligations as large, systemically important ones.

    The principle of proportionality should guide the application of such rules, ensuring that smaller, stable institutions are not subject to the same complex obligations that threaten their competitiveness and capacity to serve local communities.

  • Launch a comprehensive review and streamlining of capital requirements and the EU financial rulebook to remove obsolete, overlapping, or excessively burdensome provisions.

    We recommend to make the review of existing capital requirements for banks. A comprehensive streamlining of the EU financial rulebook is needed.

  • Streamline and harmonize supervisory processes, particularly the Supervisory Review and Evaluation Process (SREP).

    Simplification must extend to supervisory processes themselves. EU and national authorities should intensify efforts to streamline and harmonize the Supervisory Review and Evaluation Process (SREP).

• Micro company, ITA Company, ITA model reads as: wants changes source
  • Implement a maximum 50% annual cap on investment outside national borders as a starting point for the initiative.

    It would therefore be appropriate to start with a maximum 50 % annual investment outside national borders.

    machine translation by the Commission, original in IT
  • Include safeguards in the initiative to address capital migration risks that could harm weaker member states.

    Investment platforms should therefore be opened up, risking capital migration to the strongest countries and weakening the most fragile ones.

    machine translation by the Commission, original in IT
• Leibniz Institute for Financial Research SAFE Academic or research institution, DEU model reads as: wants changes source
  • Complete the Banking Union through joint deposit insurance and resolution mechanism.

    -Completing the Banking Union through joint deposit insurance and resolution mechanism.

  • Advance the Savings and Investment Union to reduce fragmentation in financial markets and enable cross-border banking operations.

    -Advancing the Savings and Investment Union to reduce fragmentation in financial markets and allow banks to operate more effectively across the EU.

  • Facilitate cross-border banking consolidation to achieve economies of scale without increasing national market concentration.

    -Facilitating cross-border banking consolidation, which can allow banks to achieve economies of scale without increasing national market concentration.

• Veblen Institute for Economic Reforms NGO, FRA; register: Non-governmental organisations, platforms and networks and similar model reads as: wants changes source
  • Replace internal model discretion with transparent, standardised rules rather than reducing capital requirements overall.

    replacing internal model discretion with transparent, standardised rules, rather than reducing overall capital levels.

  • Preserve the CCyB/SyRB distinction in buffer reform and prioritise more proactive CCyB deployment rather than merging instruments.

    We propose that buffer reform preserve the CCyB/SyRB distinction and prioritise more proactive CCyB deployment rather than instrument consolidation.

  • Maintain and strengthen the prudential framework's engagement with climate- and nature-related financial risks.

    We propose that the prudential frameworks engagement with climate- and nature-related financial risks be maintained and strengthened.

• Micro company, FRA Other, FRA model reads as: wants changes source
  • Ease capital pressure on banks to enable them to finance large-scale investments identified by the Draghi report.

    If this surge materialises, then it is clear that the banking system will not be able to cope with these needs, if capital pressure is not eased, and that the development of capital markets will take time.

    machine translation by the Commission, original in FR
  • Transform the Banking Union from a crisis-focused model to a development-focused model.

    It is high time to change software and move from a 'Banking [Crisis] Union' to a 'Banking [Development] Union'.

    machine translation by the Commission, original in FR
  • Prioritize completing European banking integration to address competitiveness issues alongside prudential considerations.

    The focus must therefore be on finalising the Union Bancaire.

    machine translation by the Commission, original in FR
• European Association on Co-operative Banks Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Implement a regulatory moratorium on new requirements that are not addressing urgent market failures.

    Such swift and concrete action should start with a regulatory moratorium on new requirements.

  • Avoid new regulations that increase compliance burden without addressing genuine market failures or existing legislative gaps.

    New regulations that increase the regulatory and compliance burden on banks that are not addressing urgent market failure or are focused purely on further detailing already existing legislation are not currently necessary.

  • Simplify through a holistic, cross-silo approach rather than gradual adjustments over long timeframes.

    Simplification should address the combined set of regulatory actions across different regulatory silos that the financial sector has to implement approach i.e. the microprudential, macroprudential, and resolution frameworks, as well as other areas where the European framework is overly complex such as in payments, or digitalisation.

• Bundesverband Öffentlicher Banken Deutschlands, VÖB Business association, DEU; register: Trade and business associations model reads as: wants changes source
  • Provide regulatory relief to enhance the competitiveness of the EU banking sector.

    The position paper outlines our key priorities for regulatory relief and sets out a number of concrete proposals to enhance the competitiveness of the EU banking sector.

  • Implement concrete proposals to enhance the competitiveness of the EU banking sector.

    sets out a number of concrete proposals to enhance the competitiveness of the EU banking sector

• Micro company, DEU Academic or research institution, DEU model reads as: wants changes source
  • Ensure that simplification efforts in EU financial law are structured in a manner that remains institutionally and methodologically robust.

    how simplification efforts could be structured in a manner that remains institutionally and methodologically robust

  • Consider the Savings and Investment Union agenda as a particular priority when structuring simplification efforts.

    particularly in light of the Savings and Investment Union agenda