Competitiveness in the single banking market

121 submissions in the snapshot (115 from organisations), portal total 121. Feedback list on the portal.

115 of 115 organisation submissions analysed; the model reads them as: opposes 3 supports 20 wants changes 69 23 held back for review (low confidence).

• Micro company, ISL Business association, ISL model reads as: supports source
  • The Commission should continue working to simplify the regulatory framework and reduce unnecessary burdens.

    Finance Iceland looks forward to the Commissions further work in this area and supports continued efforts to identify opportunities to simplify the regulatory framework, reduce unnecessary burdens and fragmentation, and ensure that European financial regulation remains fit for purpose in markets of different sizes and characteristics.

• Reclaim Finance NGO, FRA; register: Non-governmental organisations, platforms and networks and similar model reads as: opposes source
  • Ensure that the initiative does not weaken provisions addressing climate, nature, and ESG risks.

    In this context, the Commission should ensure that the proposed initiative do not impact provisions related to climate, nature and ESG risk.

  • Avoid introducing a competitiveness mandate in financial supervision.

    Finally, Reclaim Finance warns about introducing a competitiveness mandate in financial supervision.

• Skandinaviska Enskilda Banken AB (publ) Company, SWE; register: Companies & groups model reads as: wants changes source
  • Remove national gold-plating, overlapping requirements, and the EU-specific Systemic Risk Buffer.

    Overlaps and duplicated requirements between Pillar 1, Pillar 2 and macroprudential capital buffers should be removed. The EU-specific Systemic Risk Buffer (SyRB) including the sectoral one should be removed.

  • Amend the final Basel III implementation as other major jurisdictions recalibrate theirs.

    The EUs concluding implementation of the new capital regime, final Basel III should be amended, as US, UK, and Canada recalibrate their Basel III implementations.

  • Transfer temporary transitional arrangements for the output floor into the standardized approach or make them permanent.

    The EUs temporary transitional arrangements for the output floor should be transferred to and fully implemented in the standardized approach.

• Genossenschaftsverband Bayern e.V. (Association of Bavarian Cooperatives) Business association, DEU; register: Trade and business associations model reads as: wants changes source
  • Establish a dedicated small bank regime with tailored rules rather than selective adjustments.

    What is needed instead is an entirely new regime with tailored rules for small banks, namely a dedicated small bank regime, similar to those already in place in other jurisdictions such as Switzerland, the US, and the UK.

  • Exempt well-capitalised small banks from risk-weighting requirements for their assets.

    Well-capitalised small banks should be exempt from the risk-weighting requirements for their assets.

  • Ensure institutional protection schemes are not impaired and avoid mutualisation of funds in deposit insurance reforms.

    From our perspective, the most important condition therefore is that proven protection systems, such as the IPS of cooperative banks, are not impaired in their effectiveness by any reform of the deposit insurance rules.

• Finance Sweden Business association, SWE model reads as: wants changes source
  • Permit credit institutions to assign a 65% risk weight to investment grade unrated corporates or make transitional arrangements permanent.

    We suggest implementing rules that permit credit institutions to assess if their credit exposures to unrated corporates are investment grade (IG), and assign such exposures a 65% risk weight.

  • Remove Article 458 and related provisions to avoid double-counting risk.

    Article 458 and related provisions should be removed as they double-count risk when combined with buffers and the output floor.

  • Remove the systemic risk buffer and align the releasable buffer with the countercyclical capital buffer.

    The releasable buffer should be an extension of the CcyB, in line with the current Basel requirements. The systemic risk buffer should be removed.

• Societe Generale Company, FRA model reads as: wants changes source
  • Review the architecture of capital requirements to prevent double counting and address the overall level of capital requirements.

    An ambitious reflection on the architecture of capital requirements appears necessary in order to avoid double counting phenomena and to ensure a more efficient allocation of capital at the service of the real economy.

    machine translation by the Commission, original in FR
  • Remove or revise certain prudential deductions, including treatments for software investments, the NPL backstop, and Prudent Valuation.

    Among the measures that can produce concrete effects quickly, the removal of certain prudential deductions deserves particular attention.

    machine translation by the Commission, original in FR
  • Ensure the finalisation of the FRTB framework maintains effective comparability with US and UK approaches to preserve an international level playing field.

    With this in mind, the finalisation of the FRTB framework will have to ensure that effective comparability is maintained with the approaches adopted in the United States and the United Kingdom.

    machine translation by the Commission, original in FR
• Polish Bank Association Business association, POL; register: Trade and business associations model reads as: wants changes source
  • Conduct a comprehensive review of proportionality across microprudential, macroprudential, and resolution requirements.

    The PBA therefore strongly supports a comprehensive review of proportionality across the entire regulatory framework, including microprudential, macroprudential and resolution requirements.

  • Make existing transitional arrangements for sovereign exposures issued in the currency of another Member State permanent.

    The existing transitional arrangements regarding sovereign exposures issued in the currency of another Member State should become permanent, especially for Member States outside the euro area.

  • Ensure the European Commission takes a proactive, balanced approach in CJEU proceedings and requests limitations on the temporal scope of rulings.

    The EC should also use the opportunity to request for limitation of the temporal scope of the CJEU rulings to the greater extent.

• Allianz SE Company, DEU; register: Companies & groups model reads as: wants changes source
  • Include the Danish Compromise in the forthcoming review of the banking framework to assess its effects on competition, prudential consistency, and financial stability.

    Allianz therefore urges the Commission to include the DC in its forthcoming review of the banking framework and to assess its effects on competition, prudential consistency and financial stability.

  • Compare the treatment of insurance participations across CRR, Solvency II, and FICOD to establish a convergent cross-sector capital framework.

    The review should compare the treatment of insurance participations under CRR, SII and the Financial Conglomerate Directive (FICOD) and seek a convergent cross-sector capital framework that ensures competitive neutrality and consistent treatment of equivalent risks.

• Romanian Association of Banks Business association, ROU; register: Trade unions and professional associations model reads as: supports source
  • Focus future reforms on reducing reporting burdens, enabling efficient capital and liquidity management, and simplifying MREL interactions.

    Priority should be given to reducing reporting burdens, enabling more efficient capital and liquidity management, simplifying the interaction between MREL and capital requirements, and reducing fragmentation arising from national discretions.

• SME UNITED Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Revise banks' ESG reporting requirements under Capital Requirement legislation to reflect voluntary standards for entities outside CSRD scope.

    This implies the need for a revision of banks ESG reporting requirements under the Capital Requirement legislation including L2 / guidelines where relevant.

  • Review the prudential treatment of forbearance measures and recalibrate the net present value threshold under Article 178(7) of CRR3.

    We see therefore the need for a review of the prudential treatment of forbearance measures, including the recalibration of the NPV threshold under Article 178(7) of the CRR3.

  • Enhance proportionality in the bank regulatory framework, particularly for small and less complex banks.

    We support enhancing proportionality of the bank regulatory framework especially for small and less complex banks with the aim to ensure a diversified banking system that allows for a tailored access for SMEs to bank financing.

• Dutch Banking Association Trade union, NLD; register: Trade and business associations model reads as: wants changes source
  • Call for stronger harmonisation, proportionate supervision, and the removal of unnecessary national macroprudential add-ons.

    The NVB therefore calls for stronger harmonisation, improvements of risk-based and proportionate supervision, removal of unnecessary national add-ons and a macroprudential framework that also recognises competitiveness.

  • Make transitional arrangements for unrated corporates and low-risk mortgages permanent and non-discretionary.

    make the transitional arrangement for unrated corporates and low-risk mortgages permanent and non-discretionary;

  • Simplify real-estate rules by eliminating the property value concept from the CRR.

    simplify real-estate rules by removing the unclear concept of property value from the CRR.

• Association of German Public Banks (Bundesverband Öffentlicher Banken Deutschlands, VÖB) Business association, DEU; register: Trade and business associations model reads as: wants changes source
  • Translate diagnoses into clear, operational measures within the announced timeline rather than remaining general.

    In our view, the credibility of the initiative will depend on translating correct diagnoses into clear, operational measures within the announced timeline.

  • Prioritise swift improvements and advance uncontroversial provisions through omnibus legislation ahead of Q1 2027.

    With a view to the legislative process announced for the first quarter of 2027, we therefore encourage the Commission to prioritise swift and tangible improvements, and to consider taking up selected, uncontroversial provisions by way of omnibus legislation, so that clear simplifications can be implemented as quickly as possible.

• Verband deutscher Pfandbriefbanken e.V. Business association, DEU; register: Trade and business associations model reads as: wants changes source
  • Adopt a two-stage legislative approach to prevent contentious Banking Union issues from delaying urgent negotiations.

    To achieve tangible improvements within a reasonable timeframe, we advocate a two-stage legislative approach.

  • Avoid scheduled post-crisis capital increases up to 2033 and permanently cap the output floor at 50%.

    Permanently fixing the output floor at its initial level of 50% would be a minimally invasive yet sufficiently effective measure.

  • Abolish the systemic risk buffer rather than merging it with the countercyclical capital buffer.

    The systemic risk buffer should be abolished rather than merged with the countercyclical capital buffer, as it goes beyond the Basel III requirements.

• German Banking Industry Committee Business association, DEU; register: Non-governmental organisations, platforms and networks and similar model reads as: wants changes source
  • Halt the phase-in of capital requirement increases and make CRR III transitional arrangements permanent.

    The Commission should halt the phase-in of the output floor and the credit conversion factor for unconditionally cancellable credit commitments and turn the CRR III transitional measures into permanent rules.

  • Separate individual thematic regulatory blocks from the single package to treat them urgently.

    It is necessary to separate individual thematic blocks, in particular in the area of prudential regulation, from the package and treat them as particularly urgent.

  • Replace the regulatory capital deduction for software assets with a 100% risk weight.

    We advocate replacing the capital deduction with a risk weight of 100%.

• Accountancy Europe NGO, BEL; register: Trade unions and professional associations model reads as: supports source
  • Ensure regulatory simplification is firmly anchored in high-quality financial reporting and independent audit.

    Such a shift should be firmly anchored in high-quality financial reporting and robust, independent audit, which remain essential foundations for financial stability, market confidence and effective risk management.

  • Foster deeper dialogue and close cooperation between all relevant stakeholders to avoid differing interpretations and achieve practical solutions.

    Meaningful simplification can only be achieved through close dialogue between all relevant stakeholders.

  • Acknowledge the differences between prudential supervisory objectives and financial reporting requirements.

    we highlighted the need for a deeper dialogue between banks, their supervisors, auditors, audit supervisors, financial market regulators and standard setters to acknowledge differences between prudential supervisory objectives and financial reporting requirements.

• European Savings and Retail Banking Group (ESBG) Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Introduce a specific prudential framework for low-risk retail and savings banks.

    In this context, ESBG reiterates its proposal to introduce a specific prudential framework for low-risk banks.

  • Remove the systemic risk buffer as part of reviewing the macroprudential framework.

    In particular, ESBG considers that the systemic risk buffer should be removed, as part of the broader effort to simplify the buffer framework and restore predictability.

  • Reduce duplicative reporting burdens and move toward integrated reporting and the report-once principle.

    ESBG strongly supports reducing duplicative and unnecessary reporting burdens, moving towards integrated reporting, common data definitions and the principle of reporting information only once.

• National Association of German Cooperative Banks (BVR) Business association, DEU; register: Trade and business associations model reads as: wants changes source
  • Establish a dedicated, proportionate regulatory framework across all three Basel III pillars for small, low-risk institutions.

    A dedicated and proportionate regulatory framework is needed for non-systemic institutions with low-risk business.

  • Enact legislative reforms for Pillar 2 to make P2R transparent and prevent P2G from acting as a binding requirement.

    A genuine realignment of Pillar 2 requires legislative action, supervisory guidance alone is insufficient.

  • Impose a minimum two-year moratorium on new reporting requirements to facilitate an integrated reporting framework.

    A successful development of an integrated reporting framework requires a moratorium of at least two years on new or significantly revised reporting requirements to avoid additional implementation and compliance costs due to separate initiatives.

• Insurance Europe Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Apply the competitiveness and simplification principles from the banking communication to the insurance sector and EIOPA's mandate.

    The EC should therefore apply the same principles when reviewing the EU insurance regulatory and supervisory framework and pursuing its broader simplif and competitiveness objectives.

  • Adopt a report once, use many approach and streamline reporting requirements.

    A genuine report once, use many approach should be pursued, supported by more effective data sharing between authorities.

  • Embed proportionality across the entire regulatory framework rather than limiting it to smaller firms.

    To achieve meaningful simplif, proportionality should be embedded across the regulatory and supervisory framework, rather than being limited to a narrowly defined regime for smaller firms.

• International Credit Insurance and Surety Association (ICISA) Business association, NLD; register: Trade and business associations model reads as: wants changes source
  • Recalibrate the prudential treatment of credit insurance under CRR 3.

    Delivering a more appropriate and realistic calibration for the prudential treatment of insurance when used as a credit risk mitigation technique under CRR 3 will significantly support the EUs aims for simplification and competitiveness.

  • Correct the existing calibration to reflect lower LGD for credit insurance.

    Correcting the existing flawed calibration would allow European banks to more effectively use a critical form of credit risk mitigation which the banks value for its performance and which can support increased lending to business across the EU and financing of projects critical to the EUs continued success.

• German Property Federation Business association, DEU; register: Trade and business associations model reads as: wants changes source
  • Freeze the Output Floor at 55% and make transitional arrangements permanent.

    ZIA therefore calls for the Output Floor to be frozen at its current level of 55% and for all transitional arrangements to be made permanent, as the current trajectory disproportionately penalises banks with large, well-performing mortgage books.

  • Integrate a permanent 65% risk weight for unrated investment-grade corporates directly into the Standardised Approach.

    ZIA welcomes the Commission's indication that it will examine removing the external rating obligation and calls for a permanent 65% risk weight for unrated investment-grade corporates to be integrated directly into the Standardised Approach.

  • Restrict the statutory NPL backstop to institutions with an NPL ratio exceeding 5%.

    ZIA calls for the NPL backstop to be restricted at minimum to institutions with an NPL ratio exceed-ing 5%.

• Lloyd's Market Association Business association, GBR model reads as: wants changes source
  • Recalibrate the prudential treatment of insurance under CRR 3 to reflect a lower LGD.

    Delivering a more appropriate and realistic calibration for the prudential treatment of insurance when used as a credit risk mitigation technique under CRR 3 will significantly support the EUs aims for simplification and competitiveness.

  • Correct the flawed calibration of credit insurance as a credit risk mitigation technique.

    Correcting the existing flawed calibration would allow European banks to more effectively use a critical form of credit risk mitigation which the banks value for its performance and which can support increased lending to business across the EU and financing of projects critical to the EUs continued success.

• ShareAction NGO, BEL; register: Non-governmental organisations, platforms and networks and similar model reads as: wants changes source
  • Develop a working definition of competitiveness that incorporates sustainability.

    Develop a working definition of competitiveness that includes a sustainability component;

  • Preserve the output floor and replace its flat risk weight with a risk-sensitive alternative.

    Preserve the output floor, replacing its flat risk weight with a risk-sensitive, non-model-based alternative;

  • Refrain from giving the EBA a competitiveness mandate.

    Refrain from granting the EBA a competitiveness mandate;

• Association française des sociétés financières Business association, FRA; register: Trade unions and professional associations model reads as: wants changes source
  • Introduce a delegated act under CRR3 to confirm a reduction in the risk weighting of leasing exposures.

    If it is conclusive, Article 495c of CRR3 provides for a delegated act by the European Commission to confirm a reduction in the risk weighting of leasing exposures.

  • Introduce a more favourable prudential treatment for factoring under the Standardised Approach for credit risk.

    It is time to make a step further and introduce a more favourable prudential treatment for factoring in CRR in the Standardized approach for credit risk better reflecting its low risk profile.

  • Adjust prudential rules to reflect the lower risk profile of asset backed financing solutions like leasing and factoring.

    To free the potential of specialized financing to better finance European competitiveness, adjusted prudential rules that really reflect the lower risk profile of asset backed financing solutions such as leasing and factoring are required.

• Groupe BPCE Company, FRA model reads as: wants changes source
  • Make the transitional arrangements for the output floor permanent.

    Making these measures permanent would preserve the risk sensitivity of the output floor.

  • Make the transitional measures for FRTB permanent and enhance the FRTB-SA framework.

    As almost all EU banks will have to apply SA, the Commission should make permanent the transitional measures and consider additional improvements to the FRTB-SA framework such as market hedges of accounting CVA, Correlation Trading Portfolio and remaining prudential boundary issues.

  • Reconsider the functioning of the NPL backstop to avoid discouraging forbearance measures.

    In particular, in a low-NPL context across Europe, the NPL backstop's functioning should be reconsidered as it discourages forbearance measures that could restore borrowers repayment capacity.

• Arch Insurance (EU) dac Company, IRL; register: Companies & groups model reads as: wants changes source
  • Make effective credit risk sharing an explicit objective across the banking competitiveness agenda.

    Arch encourages the Commission to make effective credit risk sharing an explicit part of the banking competitiveness agenda and carry this objective through into all relevant files.

  • Recognise eligible insurers from Solvency II equivalent regimes under STS criteria.

    Reforms should instead recognise eligible insurers, including EU insurers from groups under Solvency II equivalent regimes where robust safeguards are met.

• ABBL - Association des Banques et Banquiers, Luxembourg Trade union, LUX; register: Trade and business associations model reads as: wants changes source
  • Review the architecture of capital requirements to remove overlaps and restore risk sensitivity.

    ABBL supports an ambitious review of the overall architecture of capital requirements to remove unnecessary overlaps, restore risk sensitivity and ensure an efficient allocation of capital to finance the European real economy, while preserving financial stability.

  • Revise the CRR SNCI framework to assess risk and complexity beyond balance-sheet size.

    Revise the CRR Small and Non-Complex Institution (SNCI) framework to better reflect risk and complexity beyond balance-sheet size.

  • Eliminate regulatory duplication and implement a genuine report once principle.

    ABBL supports a genuine report once principle.

• European Fintech Association (EFA) Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • The Commission should strengthen enforcement against IBAN discrimination, ensure mutual recognition of remote onboarding and KYC, and embed a report once approach.

    We therefore encourage the Commission to: (i) strengthen enforcement against IBAN discrimination and restrictions on nonlocal and virtual IBANs, (ii) ensure mutual recognition of remote onboarding and KYC, building on the single AML rulebook and the European Digital Identity Wallet so that onboard once effectively means onboard across the EU, and (iii) embed a clear report once and datareuse approach in prudential, resolution and statistical reporting, with stronger limits on additional national reporting.

  • The Commission should revisit the calibration of operational risk capital and review the treatment of central bank reserves in the leverage ratio.

    EFA would therefore support bringing these issues into scope of this work and in doing so ask the Commission to: (i) revisit the calibration of operationalrisk capital so that same risk, same capital applies regardless of revenue mix and (ii) review the treatment of central bank reserves in the leverage ratio and, more generally, introducing a standing flexibility mechanism to adjust timing or calibration where there is significant divergence from other major jurisdictions.

• Federcasse Business association, ITA; register: Trade and business associations model reads as: wants changes source
  • Proportionality should be applied taking into account business models serving the real economy to address disparities between IPS-aggregated banks and cross-guarantee mechanism SNCIs.

    We also stress that, if properly understood, proportionality should be implemented taking into account business models serving the real economy, with a view to supporting broad-based and inclusive European growth. A coherent and effective proportionality regime would help address the significant disparity in treatment between small and non-complex banks that aggregate through an IPS and SNCI that aggregate sometimes as a result of regulatory requirements through a cross-guarantee mechanism (pursuant to Article 4(1), point 127, CRR).

  • The SNCI category criteria should be complemented by an overarching qualitative criterion concerning the institution's purpose or objective.

    Furthermore, the criteria defining the SNCI category should be appropriately complemented by an overarching qualitative criterion relating to the purpose or objective pursued by the institutions concerned.

  • A structured and broader proportionality regime should encompass not only prudential requirements, but also reporting, disclosure, and governance obligations.

    A greater and more structural degree of proportionality should concern not only prudential requirements in the strict sense, but, as far as possible, also reporting, disclosure and governance obligations which may generate significant costs.

• Spanish Banking Association Business association, ESP; register: Trade and business associations model reads as: wants changes source
  • EU supervisory authorities should be given a formal secondary competitiveness objective along with enhanced accountability and cost-benefit assessments.

    A key priority should be the introduction of a formal secondary competitiveness objective for EU supervisory authorities, accompanied by more accountability, systematic cost-benefit analysis and assessments of the cumulative impact of supervisory/regulatory measures on financing, investments, market integration and international competitiveness.

  • Targeted revisions should be made to prudential rules, including making operational risk transitional arrangements permanent and removing the prudential NPL backstop.

    We call for targeted revisions to prudential rules. These include making permanent transitional arrangements relating to operational risk, notably the ILDC and UCCs, as well as the removal of the prudential NPL backstop, which is considered an example of EU gold-plating that undermines the global competitiveness of EU banks.

  • The Banking Union should be completed through a fully-fledged EDIS before any sovereign exposure reforms are implemented.

    We need to complete BU through a fully-fledged EDIS. We consider EDIS essential to reduce fragmentation, strengthen financial stability and support cross-border banking integration. Accordingly, any discussion on reforms to the prudential treatment of sovereign exposures should only take place in parallel with, and be explicitly linked to, the completion of BU, including EDIS and effective liquidity-in-resolution arrangements.

• Deutsches Aktieninstitut e.V. Business association, DEU; register: Trade and business associations model reads as: wants changes source
  • Supervisory practice on trade finance should align with the 20% credit conversion factor, and the unrated corporate standard risk weight exemption should be made permanent.

    In the paper, we called for supervisory practice on trade finance to be aligned with the 20% credit conversion factor set out in Annex I CRR and for the exemption from the standard risk weight for unrated corporates under Art. 122 CRR to be made permanent.

  • The reduced SA-CCR alpha factor of 1.0 for derivative exposures with non-financial counterparties under the output floor calculation should be made permanent.

    In this context, we however miss a clear commitment to make permanent the reduced SA-CCR alpha factor of 1.0 for derivative exposures with non-financial counterparties under the output floor calculation, which is currently set to expire in 2029.

  • Targeted technical amendments should be separated from broader political integration negotiations into distinct proposals.

    For this reason, targeted amendments to the prudential framework and broader integration topics could be addressed with two different proposals.

• Association of Proprietary Traders Business association, NLD; register: Trade and business associations model reads as: wants changes source
  • The Commission and EBA/ESMA recommendations on the investment firms prudential framework should be addressed without delay.

    This is why we feel the issues identified by the Commission and by the EBA/ESMA recommendations need to be addressed without delay.

  • The IFR/IFD regime should be revised to move away from balance-sheet thresholds toward risk-sensitive assessments, improve K-CMG calibration, and increase proportionality for smaller proprietary trading firms.

    Under those areas, it will be useful to revise the regime to move away from the automatic reclassification based on balance-sheet thresholds to a more risk-sensitive assessment, improve the calibration of K-CMG and make the framework more proportionate for smaller sized proprietary trading firms.

  • A dedicated legislative vehicle should be brought forward for investment firms rather than tying reforms to broader banking package negotiations.

    Therefore, APT would urge the Commission to bring forward a specific legislative vehicle for the investment firms prudential framework, rather than making these targeted reforms dependent on the timing of a broader banking package negotiations.

• Association of International Banks in Germany Business association, DEU; register: Trade and business associations model reads as: supports source
  • Apply proportionality consistently across the EU regulatory framework according to institution size, complexity, business model, and risk profile.

    We therefore strongly support the Commissions overall emphasis on strengthening the application of proportionality in the EU regulatory framework. Requirements should be commensurate with the size, complexity, business model and risk profile of institutions, while maintaining the necessary level of prudential safeguards.

  • Prevent regulatory goldplating effectively by restricting divergent national requirements.

    We also strongly support the Commissions intention to prevent regulatory goldplating effectively. Where EU legislation provides for harmonised requirements, additional or divergent national requirements should only be introduced where clearly justified and in line with the objectives of the EU framework.

  • Ensure greater consistency and harmonisation of regulatory requirements and supervisory practices across Member States.

    Greater consistency and harmonisation of regulatory requirements and supervisory practices across Member States are therefore key prerequisites for strengthening the EU banking sectors competitiveness.

• BNP Paribas Company, FRA model reads as: wants changes source
  • Adopt a game-changing legislative package by Q1 2027 through an accelerated legislative process.

    In light of this, we advocate for a game-changing legislative package no later than Q1 2027, followed by an accelerated legislative process.

  • Repeal the NPL backstop and the Prudent Valuation rules.

    repealing the NPL backstop and the Prudent Valuation rules;

  • Introduce a formal economic growth and competitiveness mandate for the EBA.

    A formal economic growth and competitiveness mandate for the EBA (something that has proved relevant and feasible in other major countries), better framing supervisory authorities' discretion through Level 1 rules and improving how their practices align with the EUs priorities combined with enhanced accountability mechanisms, are key for laying out a virtuous and balanced framework which will enable Europe to meet its numerous challenges.

• BNY SA/NV Company, BEL; register: Companies & groups model reads as: wants changes source
  • Exclude risk-free central bank deposits from the calculation of the leverage ratio.

    BNY believes that central bank deposits should be excluded from the calculation of the leverage ratio as they are risk-free.

  • Enhance the design and targeting of Pillar 2 guidance by incorporating post-stress CET1 ratios and calculating depletion relative to original CET1.

    In order to make the P2G more targeted, we believe that the EU authorities should consider: Incorporation of post-stress CET1 ratios into the setting of P2G add-ons. Calculation of depletion as a proportion of a firms original CET1, not as a percentage point decrease. Incorporation of recovery and management actions into stress test results, in line with the approach in other jurisdictions. Explicit guidance to authorities to disapply the non-binding P2G where it is not appropriate for the business model.

  • Delete prudential limits on bank deposits from the MiCA framework and reconsider them within the CRR liquidity framework.

    Prudential rules for banks, including the 1.5% should be deleted from the MiCA framework and reconsidered in the context of the existing liquidity framework in CRR.

• European Banking Federation Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Eliminate specific EU goldplating measures including the Systemic Risk Buffer, Prudent Valuation Adjustment, and NPL backstop.

    EU Goldplating such as the Systemic Risk Buffer, the Prudent Valuation Adjustment and the NPL backstop should be eliminated.

  • Cap the O-SII buffer at 0.75% and eliminate duplications between O-SII and G-SII buffers.

    Cap O-SII buffer at 0.75% and eliminate duplications between O-SII and G-SII buffers.

  • Make all CRR3 transitional arrangements permanent and extend them to the standardised approach.

    European specificities: all CRR3 transitional arrangements should be made permanent and extended to the standardised approach to avoid detrimental effects on low-risk mortgages, unrated corporates, client risk hedging, operational risk, UCCs, among others.

• Austrian Savings Banks Association Business association, AUT model reads as: wants changes source
  • Establish an EU-specific regulatory framework for low-risk banks to provide operational relief and foster SME lending.

    We call for an EU-specific regulatory framework for low-risk banks, accessible to a broad range of savings and retail banks, providing substantial operational relief and freeing capacity for SME lending.

  • Make CRR transitional provisions permanent, including lower risk weights for unrated corporates and low-risk mortgages.

    The CRR transitional provisions must become permanent: lower risk weights for unrated corporates and low-risk mortgages, and a zero risk weight for exposures to MS central governments and central banks denominated and funded in another MS domestic currency.

  • Exempt recognised institutional protection schemes with deposit guarantee functions from any future EDIS.

    It would therefore be consequent to exempt recognised IPS with deposit guarantee functions from EDIS.

• Inbonis Rating Company, ESP model reads as: wants changes source
  • The Commission should preserve regulatory recognition of external credit assessments in the CRR framework.

    We respectfully encourage the Commission to preserve the regulatory recognition of external credit assessments within the CRR framework, while addressing transitional disincentives and supporting broader rating coverage of European corporates.

  • The EU should not address the limited availability of ECAI ratings by reducing the relevance of external credit assessments.

    Europe should not address the (not so) limited availability of ECAI ratings by reducing the relevance of such information.

  • The EU should use the transitional period to expand independent and comparable credit ratings for European companies.

    Instead, the EU should build the policy logic already embedded in CRR3 and use the transitional period to expand the availability of independent, comparable and proportionate credit ratings of European companies.

• Unipol Assicurazioni S.p.A. Company, ITA; register: Companies & groups model reads as: wants changes source
  • The Commission should extend its competitiveness initiative to the insurance sector and other financial sectors.

    Given the merits of these objectives, we invite the Commission to extend this initiative to the insurance sector, as to other relevant financial sectors.

  • The Commission should review FICOD and Solvency II to eliminate regulatory arbitrage by introducing a mechanism similar to the Danish Compromise for insurance-led conglomerates.

    In light of this, we invite the Commission to review FICOD and Solvency II with a view to removing existing regulatory arbitrage by introducing a prudential mechanism similar to the DC for insurance-led conglomerates.

• Bundesverband der Wertpapierfirmen (bwf) Business association, DEU; register: Trade and business associations model reads as: wants changes source
  • Creeping realignment of investment firms with the bank credit-institution regime must be avoided, while preserving FRTB optionality and higher Class 3 thresholds.

    Therefore, any creeping realignment with credit-institution regime should be avoided. The optionality of FRTB application and higher Class 3 thresholds (200m / 50m) should be preserved.

  • Costly K-factor monitoring requirements should be eased for firms where the fixed overheads requirement remains constantly determining.

    For firms who can demonstrate that FOR remains constantly the determining factor over a certain period of time, the costly K-factor monitoring requirements should be eased.

  • Perfect hedges for crypto-assets should be recognised and the prohibitive 1% Tier 1 cap dropped.

    Perfect hedges should be recognised and the prohibitive 1% cap dropped.

• Revolut Company, LTU; register: Companies & groups model reads as: wants changes source
  • The Commission should revisit the treatment of the exposure measure and central bank claims where the leverage ratio has become binding.

    Revisiting their treatment would serve the Commission's own buffer usability objective.

  • The calibration of operational risk should be reviewed alongside software asset treatment to restore downward recognition for low losses.

    We recommend reviewing this calibration alongside the announced revision of software asset treatment.

  • The commitment that supervisory practices be neutral regarding organizational models should be given legal effect.

    We support the commitment that supervisory practices be neutral as to a bank's organisational model and not discourage activity through branches or the free provision of services, and recommend it be given legal effect.

• Krajowy Związek Banków Spółdzielczych (National Association of Cooperative Banks), Warsaw, Poland Other, POL model reads as: wants changes source
  • The principle of proportionality must be translated into specific reductions of regulatory obligations beyond extending the SNCI definition.

    At the same time, we would like to emphasise that the extension of the definition of SNCI will not be enough. It is necessary to translate the principle of proportionality into a specific, measurable reduction of obligations.

  • Reporting obligations should be reduced in scope, frequency, and complexity.

    1. Reduce the scope, frequency and complexity of reporting

  • Capital requirement calculation methods, liquidity requirements, and MREL should be simplified and adjusted with recognition of IPS membership.

    4. Proportional MREL and recognition of IPS membership

• TNI Academic or research institution, NLD model reads as: opposes source
  • Simplification and harmonisation of capital rules should not reduce any prudential requirements.

    Simplification of the capital stack and harmonisation of national (macro-prudential) rules and supervision should therefore not reduce any of the prudential requirements.

  • Supervisor mandates under CRR III should be strengthened to curb bank payouts in dividends and share buybacks.

    Strengthen supervisor mandates (CRR III Art. 78 ) to reduce bank payouts in dividends, and especially share buybacks that cancel equity (based on MAR, Art. 5) if banks aim to only increase return on equity, reduce risk appetite, neglect expenditures to strengthen cybersecurity, disregard expenditures and reserves to implement impactful prudential transition plans (avoid climate related stranded assets, increase climate future proof exposure).

  • Targeted changes to the IFR/IFD framework should not reduce the resilience of investment firms.

    The EC bank report proposals on targeted changes of IFR/IFD should not reduce the resilience of the ever more risk-taking and profit driven investment firms, but rather support EU businesses.

• EBA CLEARING Company, FRA model reads as: supports source
  • EU policy should leverage existing pan-European account-to-account payment infrastructures to foster an integrated payments ecosystem.

    The EU Institutions policy should support the leveraging of these existing building blocks to further develop and foster an integrated and competitive European payments ecosystem.

  • A collaborative public-private infrastructure landscape should be preserved to avoid single points of failure.

    To maintain choice, resilience, competition and innovation, it is important that a private-public infrastructure collaborative landscape is preserved, avoiding single dependencies and points of failure.

  • A level playing field between public and private infrastructure providers should be maintained.

    A level playing field between public and private infrastructure and service providers is also crucial to stimulate competition and innovation and preserve choice for financial institutions.

• European Association on Co-operative Banks Business association, BEL model reads as: wants changes source
  • The Commission should launch a legislative review of the prudential framework without further delay.

    We thus support the launch of a legislative review without further delay.

  • The upcoming impact assessment should analyse regulatory effects beyond sectoral averages, accounting for different institution types, asset classes, and financing needs.

    We also encourage the Commission, in the impact assessment that will accompany the proposal, to analyse the effects of regulation beyond sectoral averages, giving due considerations to the impact of rules on different types of institutions, asset classes, as well as capital and financing needs.

  • The Commission should establish a more proportionate and risk-based framework reflecting the specificities of cooperative banks.

    We believe that the EC should strive to achieve a more proportionate and risk-based framework for all banks taking into account the complexity of their business model and their legal and organisational features, duly reflecting cooperative banks specificities.

• CECA Business association, ESP; register: Trade and business associations model reads as: supports source
  • Prioritise supervisory simplification and accountability through Pillar 2 simplification and enhanced transparency.

    Supervisory simplification and accountability must be prioritised through the simplification of Pillar 2, greater supervisory transparency and predictability; better coordination between microprudential, macroprudential and resolution frameworks; a clearer distinction between binding requirements and soft law; and strengthening the accountability of supervisory authorities.

  • Improve regulatory governance by streamlining Levels 2 and 3 and reforming the EBA with a competitiveness mandate.

    Regulatory governance should be improved through streamlining Levels 2 and 3, a reform of the EBA with a competitiveness mandate; improved impact assessments; periodic reviews of guidelines and Q&As; and limiting regulatory proliferation.

  • Apply proportionality beyond entity size by taking into account low risk profiles and sound business models.

    Proportionality is a key issue, but, in our view, size is not the only relevant metric: bigger entities with a low risk profile, reduced complexity and a sound business model, should also be taken into account when devising a simplified regime.

• French Banking Federation Business association, FRA model reads as: wants changes source
  • Make the output floor level and transitional arrangements permanent.

    The level of the output floor and its transitional arrangements for residential mortgages, unrated corporates and counterparty risks should be made permanent.

  • Pursue an ambitious reform of the macroprudential framework by simplifying buffer architecture and preventing continuous capital increases.

    The Commission should also pursue an ambitious reform of the macroprudential framework, simplifying the buffer architecture, reviewing national buffers that go beyond identified systemic risks and preventing the continuous increase of capital requirements that progressively reduces banks' financing capacity.

  • Embed competitiveness, growth, and real economy financing objectives across the regulatory and supervisory framework.

    The Commission should ensure that the objectives of competitiveness, growth and financing the real economy are consistently embedded throughout the regulatory and supervisory framework, as is the case in other major jurisdictions ; they should be embedded in ESA mandates and impact assessments.

• Banco Santander Company, ESP; register: Companies & groups model reads as: supports source
  • Systematically integrate growth and competitiveness into supervisory mandates.

    European supervisory authorities, including the ECB in its supervisory role within the Single Supervisory Mechanism, should systematically consider how their decisions affect financing, investment, bank competitiveness, market integration and the Unions open strategic autonomy, while financial stability remains paramount.

  • Make temporary treatments permanent or extend them on a stable basis.

    Temporary approaches that have proved necessary to avoid disproportionate capital requirements, without weakening banks resilience, should be made permanent or extended on a stable basis.

  • Recognise the international presence of European banks and avoid unjustified prudential penalties for operating in third countries.

    Where local regulatory and supervisory frameworks deliver outcomes equivalent or comparable to EU standards, the EU should recognise them appropriately to avoid duplicated requirements and disproportionate capital charges.

• Bank of Valletta p.l.c Company, MLT model reads as: supports source
  • Give greater consideration to the cumulative burden arising from regulatory and supervisory requirements.

    In this regard, greater consideration of the cumulative burden arising from regulatory and supervisory requirements would help ensure that institutions can continue to focus resources on supporting customers, businesses and wider economic activity.

  • Ensure regulatory and supervisory expectations appropriately reflect institutional nature, scale, and complexity.

    Regulatory and supervisory expectations should appropriately reflect the nature, scale and complexity of institutions and their activities.

  • Continue work towards greater harmonisation and enhanced data sharing to streamline reporting frameworks.

    Continued work towards greater harmonisation, enhanced data sharing between authorities and increased re-use of existing information would contribute to a more efficient reporting environment.

• Erste Group Company, AUT; register: Companies & groups model reads as: wants changes source
  • Introduce targeted waivers for intragroup large exposures and re-adjust Basel risk weights in targeted areas.

    Besides improving the mobility of capital and liquidity by introducing targeted waivers for intragroup large exposures, policymakers should also re-adjust the Basel implementation in a proportionate manner in some targeted areas, and ensure that risk weights better reflect economic realities, including for low-risk mortgages, unrated corporates, sovereign exposures, and equity investments supporting innovation (e.g. make current transitional measures permanent, restore previous risk weights).

  • Reform the systemic risk buffer so that it is not stacked on top of other buffers.

    In particular, the SyRB should be reformed. It should also not be stacked on top of the G-SII/O-SII buffers, but the higher of the two should apply.

  • Streamline reporting requirements and supervisory processes under a report once principle.

    Europe should therefore fully commit to a fast-tracked report once, use multiple times principle, establish a more integrated reporting architecture across authorities, simplify stress testing, and increase coordination among supervisory bodies.

• UNI Europa Finance Trade union, BEL model reads as: wants changes source
  • Recognise workers, social dialogue, and collective bargaining in upcoming legislative proposals.

    We ask the Commission to ensure that workers, social dialogue and collective bargaining are explicitly recognised as part of a competitive EU banking sector in the legislative proposals due in the first quarter of 2027.

  • Preserve prudential lessons from the 2008 financial crisis rather than treating them as obstacles to competitiveness.

    Eighteen years on from the largest financial crisis in living memory, the prudential lessons of 2008 should not be treated as an obstacle to competitiveness.

• CaixaBank Company, ESP; register: Companies & groups model reads as: supports source
  • Address overlaps and double counting across Pillar 1, Pillar 2, macroprudential buffers, leverage, and resolution requirements.

    At the same time, the review of the capital framework should address overlaps and double counting across Pillar 1, Pillar 2, macroprudential buffers, leverage and resolution requirements, with the objective of creating a more coherent and risk-sensitive framework.

  • Ensure any future review of the output floor remains evidence-based and carefully calibrated.

    Any future review of the output floor framework should remain evidence-based and carefully calibrated, considering its interaction with the wider prudential framework and the need to preserve regulatory stability.

  • Focus on reducing duplication and enhancing proportionality in reporting and disclosure requirements.

    Efforts should focus on reducing duplication, enhancing proportionality and promoting more integrated reporting frameworks.

• Loan Market Association Business association, GBR; register: Trade and business associations model reads as: wants changes source
  • Review whether the permanent Pillar 1 non-performing loan backstop continues to operate as intended across different economic conditions.

    Against this background, it is appropriate to consider whether all aspects of the current framework continue to operate as intended across different market conditions and economic circumstances.

  • Examine technical features in the ECB leveraged transactions guidance that inappropriately classify credit without elevated leverage risk.

    However, members have reported instances where certain technical features of the methodology, including undrawn facilities, accordion capacity, and debt-incurrence baskets, may affect supervisory classification even where actual indebtedness and borrower fundamentals do not indicate elevated leverage-related risk.

• Fédération Européenne de Finances et Banques Ethiques et Alternatives Business association, BEL; register: Non-governmental organisations, platforms and networks and similar model reads as: wants changes source
  • Ensure capital is directed toward the real economy and the green and just transition rather than pursuing broad deregulation.

    We consider that ensuring capital flows towards the real economy, and the green and just transition should be a central objective of this review.

  • Avoid introducing a competitiveness mandate into financial supervision.

    We therefore warn against introducing a competitiveness mandate in financial supervision, since this mandate risks undermining the financial stability mandate of the supervisor.

  • Limit higher risk tolerance strictly to specific areas like climate transition and SME lending rather than applying it broadly.

    While the report calls for a higher tolerance for risk, we caution that this should apply only to specific sectors - namely climate mitigation and adaptation, transition finance, and SME lending - and not be extended broadly.

• European Association of Public Banks Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Incorporate business model and risk profile alongside size when determining eligibility for the proportionate regime.

    We therefore encourage the Commission, as it prepares its legislative proposals for the first quarter of 2027, to ensure that proportionality is holistic and risk-based, combining size with business model, risk profile, domestic focus, public-mandate status and systemic relevance.

  • Deliver tangible and risk-based supervisory and reporting relief for low-risk institutions.

    We therefore strongly support the Communications emphasis on supervisory and reporting simplification, and encourage the Commission and the ESAs to ensure that these commitments translate into tangible, measurable and risk-based relief for low-risk institutions.

• Anasf Business association, ITA; register: Trade and business associations model reads as: wants changes source
  • Promote greater harmonisation and remove unjustified cross-border obstacles to capital, liquidity, and services within groups while safeguarding prudential stability.

    Anasf therefore supports greater harmonisation of the European framework and the removal of the unjustified obstacles identified in the Communication to the movement of capital, liquidity and services within groups, whilst respecting prudential safeguards and financial stability.

  • Improve creditworthiness assessment processes to take a broader view of applicants' circumstances while developing integrated capital markets.

    It is therefore necessary to improve creditworthiness assessment processes so that they take a more comprehensive view of applicants economic and financial circumstances.

  • Safeguard cost transparency, advisory relationship quality, and existing levels of customer protection when revising distribution rules.

    Anasf therefore considers it essential that any European initiative should safeguard not only the indispensable transparency of costs and incentives, but also the quality of the professional relationship and access to a qualified advisory service.

• International Underwriting Association Company, GBR model reads as: wants changes source
  • Ensure the efficient provision of credit insurance risk mitigation to European banks as a policy priority.

    Ensuring the efficient provision of risk mitigation to European banks by robustly regulated, diversified, and non-correlated insurance undertakings should be a priority within these efforts.

  • Recalibrate the prudential treatment of credit insurance under CRR 3 by applying a lower loss given default.

    Delivering a more appropriate and realistic calibration for the prudential treatment of insurance when used as a credit risk mitigation technique under CRR 3 will significantly support the EUs aims for simplification and competitiveness.

• Austrian Federal Economic Chamber Business association, AUT model reads as: wants changes source
  • Ensure that initiatives benefit both large cross-border banking groups and domestic, traditional banks.

    We therefore call on the Commission, ECB and NCAs to truly ensure that this and future initiatives benefit both large crossborder banking groups and domestic, traditional banks as both are essential for keeping the EU competitive.

  • Embed competitiveness as a core policymaking objective supported by ex-ante impact assessments.

    Competitiveness should therefore become a core consideration in policymaking, supported by ex-ante assessments and impact assessments of the effects on lending, investments and the European economys ability to compete globally.

  • Prioritise Level 1 legislation and withdraw or repeal rules that harm competitiveness.

    Greater emphasis should be put on Level 1 regulation (reducing regulations on Level 2/3), while reducing national gold-plating and removing national measures that unnecessarily restrict lending.

• Finansforbundet Trade union, DNK; register: Trade unions and professional associations model reads as: wants changes source
  • Ensure that regulatory simplification does not lead to general deregulation or undermine financial stability and worker protections.

    Simplification must not become a general deregulation agenda or weaken financial stability, consumer protection or workers rights.

  • Adopt a broader concept of competitiveness that includes skills development, attractive workplaces, and local employment.

    The Commission should apply a broader concept of competitiveness.

  • Preserve operational capacity, decision-making authority, and social dialogue in national banking markets.

    Social dialogue, collective bargaining and information and consultation rights must be respected when reforms affect work organisation and employment.

• WWF European Policy Office NGO, BEL; register: Non-governmental organisations, platforms and networks and similar model reads as: wants changes source
  • Maintain existing prudential safeguards and reporting requirements rather than weakening them in the name of competitiveness.

    Weakening prudential requirements would therefore risk increasing systemic vulnerabilities without delivering clear competitiveness benefits.

  • Ensure the banking system integrates climate- and nature-related risks into the prudential framework.

    In this context, initiatives aimed at enhancing the competitiveness of the banking sector should not come at the expense of the progress made in integrating climate- and nature-related risks into the prudential framework.

  • Do not introduce a competitiveness mandate for financial supervisors.

    WWF also cautions against introducing a competitiveness mandate for financial supervisors.

• Deutsche Börse Group Company, DEU; register: Companies & groups model reads as: supports source
  • Enhance proportionality and eliminate overlapping regulatory requirements for Central Securities Depositories.

    From the perspective of a leading international market infrastructure provider, our core recommendation is to enhance the principle of proportionality and address overlapping and duplicative regulatory requirements such as those currently faced by Central Securities Depositories (CSDs).

  • Exempt Central Securities Depositories from the BRRD MREL framework.

    Specifically, exempting these specialized infrastructures from the BRRDs MREL framework would better align their regulatory and prudential requirements with their low-risk profile.

32 more analysed submissions on the consultation page.