Association for Financial Markets in Europe

AFME

AFME represents leading global and European banks and other significant capital market players, advocating for deep and integrated European capital markets that serve the needs of companies and investors.

Lobbying Activity

Meeting with Michalis Hadjipantela (Member of the European Parliament)

20 Nov 2025 · Meeting about Taxonomy Delegated Act

Meeting with Giovanni Crosetto (Member of the European Parliament, Shadow rapporteur) and Unipol Assicurazioni S.p.A:

21 Oct 2025 · Securitisation Framework

Meeting with Martin Merlin (Director Financial Stability, Financial Services and Capital Markets Union)

15 Oct 2025 · The development of the EC’S SIU strategy

Finance Industry Seeks Cyber Resilience Act Exemption to Avoid DORA Overlap

14 Oct 2025
Feedback on — EU digital simplification package reviewing cybersecurity, AI, and data sharing regulations.
Their ask — AFME requests exemption from the Cyber Resilience Act, arguing financial services already comply with equivalent DORA requirements. They highlight significant overlap between CRA product regulations and DORA's entity-level requirements affecting digital banking apps, payment systems, and IT infrastructure. They also seek clarifications on AI Act definitions and a reassessment of the Financial Data Access regulation.123
How it helps them — This would eliminate duplicate compliance obligations and free up resources during live incidents.45
Who loses — Consumer protections may be weakened if CRA oversight is removed from digital financial products.

Meeting with Nicolo Brignoli (Cabinet of Commissioner Valdis Dombrovskis)

14 Oct 2025 · Simplification

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

10 Oct 2025 · SIU: equity trading structure

Meeting with Mattias Levin (Acting Head of Unit Financial Stability, Financial Services and Capital Markets Union)

9 Oct 2025 · Digital omnibus

Meeting with Almoro Rubin De Cervin (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

2 Oct 2025 · Securitisation – AFME’s comments on the Commission’s securitization package

Meeting with Ralf Seekatz (Member of the European Parliament, Rapporteur) and

1 Oct 2025 · Verbriefung

Meeting with Almoro Rubin De Cervin (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

24 Sept 2025 · Level 2 measures

Meeting with Jennifer Robertson (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

11 Sept 2025 · CSDR

Meeting with Angelika Niebler (Member of the European Parliament)

24 Jul 2025 · Omnibus I, CSRD and CSDDD

Finance Industry Backs Auto-Enrolment Pensions with Tax Incentives

18 Jul 2025
Feedback on — EU recommendation on auto-enrolment and tracking systems for supplementary pensions.
Their ask — AFME recommends that member states promote auto-enrolment supplementary pension schemes with opt-out options and attractive tax incentives. They suggest state-wide administration facilities and flexible contribution rates that can increase gradually over time.123
How it helps them — This would direct retail savings into capital markets and productive investments.45
Who loses — Public budgets lose short-term revenue from tax incentives for pension schemes.6

Financial industry urges lower haircuts for securitisation HQLA eligibility

15 Jul 2025
Feedback on — Amendments to Liquidity Coverage Ratio rules for securitisation eligibility in bank liquidity buffers.
Their ask — AFME requests lower haircuts for securitisations in banks' liquid asset buffers. They propose 15% for standard STS securitisations and 10% for resilient STS transactions. They also seek removal of the requirement that securitisations must be STS-labelled to qualify.1234
How it helps them — This would allow their members to hold more securitisations as liquid assets with lower capital charges.56
Who loses — Not clearly specified who would be harmed by these proposed changes to technical liquidity requirements.

Financial industry urges inclusion of carbon removals in EU ETS

8 Jul 2025
Feedback on — Review of EU Emissions Trading System and Market Stability Reserve regulations.
Their ask — The organizations want permanent carbon removals certified under the CRCF allowed for EU ETS compliance. They support direct purchase of removal credits by regulated entities and phased integration with safeguards. They also advocate for linking EU and UK carbon markets.123
How it helps them — This would provide their members more cost-effective compliance options and improve market liquidity.45
Who loses — Climate integrity could suffer if removals substitute for actual emissions reductions.6

Financial industry urges flexible EU investment account framework

8 Jul 2025
Feedback on — European Commission proposal for standardized savings and investment accounts across EU member states.
Their ask — AFME requests flexibility in account features, allowing frameworks with varied investment universes and holding periods. They advocate for simple account structures, attractive tax incentives, and portability between providers. The organization wants existing successful schemes preserved rather than replaced.123
How it helps them — This would enable their members to scale products across borders and reduce operational costs.4
Who loses — Advocates for directing capital to EU economy lose stricter investment requirements and holding periods.5

Meeting with Jonás Fernández (Member of the European Parliament)

8 Jul 2025 · Saving and Investment Union

Meeting with Gilles Boyer (Member of the European Parliament)

8 Jul 2025 · SIU, securitisation, omnibius simplification

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

7 Jul 2025 · MiFIR – market consolidation

Meeting with Yann Germaine (Acting Head of Unit Financial Stability, Financial Services and Capital Markets Union)

26 Jun 2025 · Exchange of views on the reform of the bank crisis management and deposit insurance framework (CMDI review)

Meeting with Manuel Mateo Goyet (Acting Head of Unit Communications Networks, Content and Technology)

25 Jun 2025 · State of play on cloud policy

Meeting with Mattias Levin (Acting Head of Unit Financial Stability, Financial Services and Capital Markets Union)

12 Jun 2025 · DLT pilot review

Meeting with Philippe Thill (Cabinet of Commissioner Maria Luís Albuquerque)

22 May 2025 · Exchange with AFME on the Retail Investment Strategy

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

21 May 2025 · Firseside chat on the state-of-play of the Sustainable Finance framework

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

14 May 2025 · Informal Workshop on the integration of EU capital market

Meeting with Matthias Ecke (Member of the European Parliament, Rapporteur)

24 Apr 2025 · Finanzmarkt-Besteuerung

Meeting with Nicolo Brignoli (Cabinet of Commissioner Valdis Dombrovskis) and

22 Apr 2025 · FIDA

Meeting with Almoro Rubin De Cervin (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

16 Apr 2025 · Financial services policies

Meeting with Mattias Levin (Acting Head of Unit Financial Stability, Financial Services and Capital Markets Union)

3 Apr 2025 · Exchange of views on the FIDA proposal

Financial industry urges suspension of Green Asset Ratio

26 Mar 2025
Feedback on — EU simplification of Taxonomy reporting requirements for sustainable finance disclosures.
Their ask — The associations request suspension of the Green Asset Ratio (GAR) pending a full review, removal of Fees & Commissions and Trading Book KPIs, and elimination of GAR from Pillar 3 disclosures. They argue the GAR does not provide meaningful information yet creates significant operational burdens for banks and their clients.123
How it helps them — This would eliminate very substantial resource requirements and operational exercises for banks.45
Who loses — Investors lose standardized metrics for comparing banks' sustainable finance contributions and green asset exposure.6

Meeting with Almoro Rubin De Cervin (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

26 Mar 2025 · Banking policy

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

25 Mar 2025 · FIDA

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

19 Mar 2025 · Discussion on transaction reporting

Financial markets association urges permanent low funding requirements for repos

6 Mar 2025
Feedback on — EU rules on securities financing transactions for net stable funding ratio calculations.
Their ask — AFME wants the EU to permanently maintain current 0%, 5% and 10% required stable funding factors for reverse repos and unsecured lending. They argue reverting to higher Basel Committee standards would harm securities dealing and increase government borrowing costs.12
How it helps them — This maintains lower funding costs for their sovereign bond market-making activities.3
Who loses — European governments face higher borrowing costs to finance their economic needs.4

Meeting with Maria Raffaella Assetta (Head of Unit Financial Stability, Financial Services and Capital Markets Union) and

4 Mar 2025 · EU financial services industry associations debrief on EU-UK Financial Regulatory Forum

Meeting with Almoro Rubin De Cervin (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

4 Mar 2025 · Exchange of views on the FRTB international implementation

Meeting with Vincent Hurkens (Cabinet of Executive Vice-President Stéphane Séjourné)

27 Feb 2025 · Simplification, Savings and Investments Union, Distributed Ledger Technology

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

13 Feb 2025 · Discussion on level 2 measures on transparency requirements for equity and non-equity instruments, synchronisation of business clocks, transaction reporting and best execution

Meeting with Jonás Fernández (Member of the European Parliament)

13 Feb 2025 · Saving and Investment Union

Meeting with Gerben-Jan Gerbrandy (Member of the European Parliament)

13 Feb 2025 · Sustainable finance

Meeting with Gilles Boyer (Member of the European Parliament)

12 Feb 2025 · Banking legislation

Meeting with Cristina Dias (Cabinet of Commissioner Maria Luís Albuquerque), Larisa Dragomir (Cabinet of Commissioner Maria Luís Albuquerque)

12 Feb 2025 · Meeting to discuss market developments

Meeting with Billy Kelleher (Member of the European Parliament)

11 Feb 2025 · Savings and Investment Union

Meeting with Elena Arveras (Cabinet of Commissioner Maria Luís Albuquerque)

11 Feb 2025 · Sustainability Omnibus

Meeting with Christophe Gomart (Member of the European Parliament)

11 Feb 2025 · Financement de la défense

Meeting with Mattias Levin (Acting Head of Unit Financial Stability, Financial Services and Capital Markets Union) and

5 Feb 2025 · Use of DLT and Tokenisation in Financial Markets

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

5 Feb 2025 · AFME's Annual Financial Services Policy Dinner

Meeting with Antonina Cipollone (Head of Unit Secretariat-General)

16 Jan 2025 · Simplification

Meeting with Kinga Kollár (Member of the European Parliament)

15 Jan 2025 · Role of the CMU to improve the competitiveness of EU’s companies and EU’s banking regulation priorities

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

14 Jan 2025 · Commodity derivatives

Meeting with Dirk Gotink (Member of the European Parliament)

13 Jan 2025 · CMU and banking regulation

Meeting with Maria Raffaella Assetta (Head of Unit Financial Stability, Financial Services and Capital Markets Union) and

9 Jan 2025 · EU-UK Financial Regulatory Forum

Meeting with Aurore Lalucq (Member of the European Parliament)

8 Jan 2025 · CMU, Securitization

Meeting with Gilles Boyer (Member of the European Parliament)

19 Dec 2024 · Securitisation

Meeting with Gilles Boyer (Member of the European Parliament) and

3 Dec 2024 · CMU

Meeting with Regina Doherty (Member of the European Parliament)

16 Jul 2024 · Financial services

Meeting with Eva-Maria Alexandrova Poptcheva (Member of the European Parliament, Committee chair)

10 Jan 2024 · Meeting regarding the Integration, Sustainability and Competitiveness report

Meeting with Jonás Fernández (Member of the European Parliament)

30 Nov 2023 · Capital markets union, securitisation and sustainable finance

Meeting with Billy Kelleher (Member of the European Parliament, Shadow rapporteur)

16 Nov 2023 · ESG Rating Transparency

Meeting with Frances Fitzgerald (Member of the European Parliament, Shadow rapporteur)

10 Nov 2023 · FIDA

Finance Industry Seeks Narrow Data Scope and Payment Compensation

1 Nov 2023
Feedback on — EU framework for financial data access across multiple financial sectors and products.
Their ask — The organization requests narrowing data scope to exclude inferred data, extending implementation timeline to 36 months, and introducing market-driven compensation mechanisms. They advocate for strong regulation of new data service providers and oppose real-time data sharing requirements.1234
How it helps them — This would protect their proprietary data investments and reduce infrastructure compliance costs.567
Who loses — Third-party data users lose access to valuable derived insights and real-time information.8

Financial Industry Seeks Clearer Rules on EU Withholding Tax Reform

18 Sept 2023
Feedback on — New EU directive on standardised withholding tax relief and faster refunds for cross-border investors.
Their ask — AFME requests clear, consistent reporting requirements and due diligence obligations across Member States, with a single EU-wide portal for registration and reporting. They emphasize that liability rules must recognize the limits of financial intermediaries' visibility into investor activities. The organization also seeks clarification on key definitions including beneficial ownership, financial arrangements, and holding periods.1234
How it helps them — This would reduce their compliance costs and operational complexity across twenty-seven countries.56
Who loses — Tax authorities could lose revenue if intermediaries lack visibility into abusive arrangements.7

Meeting with Eero Heinäluoma (Member of the European Parliament, Shadow rapporteur) and WWF European Policy Programme

15 Sept 2023 · Retail investment strategy

Meeting with Mairead McGuinness (Commissioner) and

14 Sept 2023 · banking regulation, Corporate Sustainability Due Diligence Directive

Finance Industry Seeks Clarity on ESG Rating Rules

1 Sept 2023
Feedback on — EU regulation on transparency and integrity of ESG rating activities.
Their ask — AFME requests the scope be clarified to avoid capturing regulated financial undertakings already subject to existing requirements. They seek efficient interactions between ratings providers and rated entities, and a workable third-country regime with interoperable requirements.12
How it helps them — This would exempt their members from duplicative regulatory requirements they already face.3

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

29 Aug 2023 · T+1 Settlement Cycle, MifiR

Financial industry urges caution on retail investment reforms

28 Aug 2023
Feedback on — EU proposal amending investor protection rules across multiple financial services directives.
Their ask — The association requests adjustments to the inducements ban, opposes prescriptive value-for-money benchmarks based primarily on costs and performance, and seeks longer implementation timelines. They argue that alternative approaches focusing on supervision and enforcement would better serve investors while maintaining market competitiveness.123
How it helps them — This would reduce compliance costs and preserve their wholesale-to-retail distribution models.456
Who loses — Retail investors may lose access to diverse investment products and tailored advice.78

Meeting with Mairead McGuinness (Commissioner) and

18 Jul 2023 · Distribution of Retail financial products

Meeting with Eva-Maria Alexandrova Poptcheva (Member of the European Parliament, Shadow rapporteur)

15 May 2023 · Listing Act

Meeting with Alfred Sant (Member of the European Parliament, Rapporteur)

9 May 2023 · Listing Act

Banking Industry Opposes EU Prospectus Length Caps and Disclosure Exemptions

28 Mar 2023
Feedback on — Proposed EU directive simplifying listing requirements to attract companies to public markets.
Their ask — AFME strongly opposes blanket proposals to cap prospectus length and remove prospectus requirements for secondary capital raises under 40%. They argue these create material risks for investors and market stability. They support certain targeted simplifications like shorter IPO prospectus availability and lower free float requirements.123
How it helps them — This would reduce their liability and litigation risks from incomplete disclosure documents.45
Who loses — Investors lose access to complete information needed for informed investment decisions.67

Finance Industry Seeks Changes to EU Crypto Tax Reporting Rules

28 Mar 2023
Feedback on — EU proposal to expand tax cooperation directive to include crypto-assets and e-money.
Their ask — The organization requests removal of extraterritorial reporting requirements for non-EU firms, alignment of reporting deadlines with existing tax regimes, and elimination of mandatory taxpayer identification numbers. They argue current proposals create conflicts with data protection laws and operational burdens.12345
How it helps them — This would reduce compliance costs by avoiding duplicate reporting systems and data conflicts.67
Who loses — Tax authorities lose timely information on crypto transactions that could identify evasion.8

Finance industry seeks flexibility in EU insolvency reform

17 Mar 2023
Feedback on — New EU directive harmonizing national insolvency laws to facilitate cross-border investment.
Their ask — The organization requests removal of mandatory court approval for asset sales and creditor committees, greater clarity on directors' permitted actions during the three-month filing period, and a safe harbour for directors trying to save companies. They want insolvency proceedings that are simpler, more efficient, and more certain.123
How it helps them — This would enable faster, cheaper insolvency proceedings without navigating court processes.45
Who loses — Debtors lose protections against rushed asset sales and potential abuse without court oversight.6

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

8 Mar 2023 · Corporate Sustainability Due Diligence

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

28 Feb 2023 · Capital Markets Union

Meeting with Gilles Boyer (Member of the European Parliament, Shadow rapporteur)

9 Feb 2023 · CRR (staff)

Meeting with Danuta Maria Hübner (Member of the European Parliament)

25 Jan 2023 · Speech at AFME Financial Services Policy Dinner

Meeting with Gilles Boyer (Member of the European Parliament, Shadow rapporteur)

16 Dec 2022 · CRR3 (staff)

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

18 Nov 2022 · MiFIR, EU bond market liquidity

Meeting with Mairead McGuinness (Commissioner) and

17 Nov 2022 · Capital Markets Union

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

7 Nov 2022 · Corporate Sustainability Due Diligence

Meeting with Peter Liese (Member of the European Parliament, Rapporteur) and

14 Oct 2022 · ETS

Meeting with Gilles Boyer (Member of the European Parliament, Shadow rapporteur)

4 Oct 2022 · CRR3 (staff)

Meeting with Jonás Fernández (Member of the European Parliament, Rapporteur)

8 Jun 2022 · EU Banking Package 2021

Financial Markets Industry Urges Halt to Mandatory Buy-in Rules

26 May 2022
Feedback on — EU regulation on settlement discipline for securities transactions and CSD operations.
Their ask — AFME requests that mandatory buy-ins not be implemented, arguing other policy tools are more appropriate for improving settlement efficiency. They support measures to prevent settlement fails, including improved CSD functionality and harmonization. If buy-ins must remain, they should be a last resort with substantial revisions to the rules.123
How it helps them — This would avoid negative impacts on liquidity and maintain competitiveness in EU markets.45
Who loses — Investors lose protection against persistent settlement failures and market inefficiency.67

Meeting with Jonás Fernández (Member of the European Parliament, Rapporteur) and Asociación Española de Banca

23 May 2022 · EU Banking Package 2021 - "Basel III rules" panel discussion

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness)

26 Apr 2022 · sustainable finance

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

26 Apr 2022 · sustainable finance

Finance industry seeks exemptions from shell entity rules

6 Apr 2022
Feedback on — EU directive preventing misuse of shell entities for tax avoidance purposes.
Their ask — AFME requests exemptions for legitimate commercial arrangements and alignment with non-EU rules. They want clear definitions, procedural protections for rebutting shell presumptions, and harmonized standards across Member States to avoid fragmentation.123
How it helps them — This would reduce compliance costs and avoid double taxation on legitimate cross-border investments.45
Who loses — Tax authorities lose tools to combat shell companies used for aggressive tax avoidance.6

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

18 Mar 2022 · Banking Package, consolidated tape

Meeting with Gilles Boyer (Member of the European Parliament, Shadow rapporteur) and UniCredit

3 Mar 2022 · EUGB (staff)

Meeting with José Gusmão (Member of the European Parliament, Shadow rapporteur)

11 Jan 2022 · EU Green Bond Standard

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness)

30 Nov 2021 · crypto-assets

Meeting with Pedro Marques (Member of the European Parliament, Shadow rapporteur)

22 Nov 2021 · AMLA

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

29 Oct 2021 · Review of the Markets in Financial Instrument Regulation

Financial industry urges clear beneficial ownership rules for withholding tax

26 Oct 2021
Feedback on — EU standardized system for withholding tax relief to reduce cross-border investment barriers.
Their ask — AFME requests clear and consistent beneficial ownership requirements alongside procedural improvements. They argue current uncertainty leads to lengthy disputes and inconsistent outcomes across member states.123
How it helps them — This would reduce lengthy disputes and provide certainty for their members' tax reclaim processes.45
Who loses — Tax authorities lose flexibility to challenge claims on beneficial ownership grounds retrospectively.6

Finance industry urges delay in sustainability reporting for banks

14 Jul 2021
Feedback on — New EU directive requiring companies to publicly report environmental and social performance information.
Their ask — AFME requests financial institutions report sustainability information 12 months after non-financial companies complete their reporting. They want phased-in requirements for non-EU exposures and exemptions for third-country operations where counterparties lack disclosure obligations.123
How it helps them — This would give banks time to collect ESG data from borrowers and investees before their own reporting deadlines.45
Who loses — Investors and civil society groups receive less comprehensive sustainability information about banks' global operations.67

Meeting with Mairead McGuinness (Commissioner)

13 Jul 2021 · the forthcoming consolidated tape proposals

Financial industry urges data harmonization before reporting overhaul

14 Jun 2021
Feedback on — EU strategy to improve supervisory data collection and reduce reporting burden.
Their ask — The organization requests that authorities establish clear data dictionaries and reduce duplicative reporting before implementing architectural changes. They urge starting with identifying the purpose behind data collection rather than focusing on existing requirements. They advocate maintaining the current push reporting approach rather than moving to a pull model.123
How it helps them — This would reduce compliance costs and allow longer adjustment periods for complex systems.45

Financial industry urges one-year delay in EU Taxonomy reporting

1 Jun 2021
Feedback on — EU rules requiring large companies to disclose alignment with sustainable investment taxonomy.
Their ask — Financial institutions should report 12 months after non-financial companies, not simultaneously. Banks need time to collect, process and verify data from borrowers before disclosing their own exposures. The proposed requirements would force banks to report without access to reliable counterparty information.123
How it helps them — This would give them time to obtain reliable data from clients before reporting.45
Who loses — Investors lose earlier transparency on which banks finance sustainable activities most.6

Meeting with Tommy De Temmerman (Cabinet of Commissioner Mairead Mcguinness)

5 May 2021 · with Cab Dombrovskis - Basel III

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

5 May 2021 · Basel implementation, sustainable finance

Meeting with Aliénor Margerit (Cabinet of Commissioner Paolo Gentiloni)

28 Apr 2021 · CRR3 legislative package

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

27 Apr 2021 · MiFIR, EU/UK regulatory and Secondary market liquidity

Meeting with Katherine Power (Cabinet of Commissioner Mairead Mcguinness), Katherine Power (Cabinet of Commissioner Mairead Mcguinness)

27 Apr 2021 · Sustainable Finance

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

27 Apr 2021 · Sustainable Finance

Meeting with Lucrezia Busa (Cabinet of Commissioner Didier Reynders)

12 Apr 2021 · Substainable Corporate Governance

Meeting with Antoine Colombani (Cabinet of Executive Vice-President Frans Timmermans) and

16 Mar 2021 · Sustainable finance, Green recovery

Meeting with Marlene Rosemarie Madsen (Cabinet of Commissioner Elisa Ferreira)

24 Feb 2021 · Sustainable Finance

Financial markets lobby urges flexibility in digital resilience rules

15 Feb 2021
Feedback on — New EU regulation on digital operational resilience for financial institutions and ICT providers.
Their ask — AFME requests a risk-based approach aligned with existing guidelines, 36-month implementation period, removal of vulnerability disclosure requirements, and elimination of restrictions on third-country providers. They argue prescriptive requirements limit flexibility and increase compliance costs.1234
How it helps them — This would reduce compliance burden and preserve their ability to use global service providers.56
Who loses — Regulators lose stronger oversight tools and ability to impose timely security requirements.7

Financial Markets Association Seeks Clarity on EU Data Governance

1 Feb 2021
Feedback on — EU regulation on governance of common European data spaces and data sharing.
Their ask — AFME requests clarity on Common European Data Spaces scope and operation, urging they facilitate cross-sector data flow and maintain a level playing field. They warn against restrictions on cross-border data transfers and request industry representation on the European Data Innovation Board.1234
How it helps them — This would preserve their ability to move data across borders for compliance and client services.5
Who loses — Public interest groups lose stronger oversight of cross-border financial data flows.

Meeting with Lucrezia Busa (Cabinet of Commissioner Didier Reynders)

26 Jan 2021 · substainable corporate governance

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness)

20 Jan 2021 · Digital finance

Meeting with Mario Nava (Director-General Structural Reform Support)

19 Jan 2021 · Update on sustainable finace ou exchange of views on sustainable finance

AFME urges clarity on crypto-asset definitions and custody liability

11 Jan 2021
Feedback on — EU regulation on markets in crypto-assets and DLT market infrastructures.
Their ask — AFME requests more technically accurate definitions of DLT and crypto-assets, clearer custody rules, and shorter pilot regime duration with more flexibility. They argue current definitions are too broad and custodial liability requirements are disproportionate, potentially deterring service provision.123
How it helps them — This would reduce legal uncertainty and compliance costs for their members providing crypto-asset services.45
Who loses — Investors lose protections if custody standards are weakened or if firms avoid providing services.6

Financial industry urges flexible approach to EU data transfer rules

10 Dec 2020
Feedback on — New EU standard contractual clauses for transferring personal data to non-EU countries.
Their ask — AFME requests flexible, proportionate implementation of new data transfer rules. They seek a three-year grace period for existing contracts, reduced audit burdens, and alignment with GDPR standards. The organization wants costs and liabilities left to commercial negotiation rather than mandated.1234
How it helps them — This would reduce compliance costs and avoid expensive repapering of existing contracts.567
Who loses — Data subjects lose stronger oversight as audit requirements and notification thresholds are weakened.89

Meeting with Mairead McGuinness (Commissioner)

10 Dec 2020 · Presentation AFME, Upconing Sustainable Finance Strategy, Future UK/EU relations.

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

23 Oct 2020 · CMU Action Plan and MiFID

Meeting with Michael Hager (Cabinet of Executive Vice-President Valdis Dombrovskis)

17 Sept 2020 · Banking and capital markets

Finance industry urges exemptions from MiFID II research unbundling rules

11 Sept 2020
Feedback on — EU proposal to adjust MiFID II research rules for SMEs and fixed income instruments post-COVID-19.
Their ask — The organization requests modifications to the proposed research unbundling exemptions, including narrowing geographic scope to EU-listed issuers only and making the regime optional for both buy-side and sell-side firms. They want simpler definitions for SME issuers using annual assessment dates rather than rolling 12-month periods. For fixed income markets, they seek comprehensive consultation before any changes.1234
How it helps them — This would reduce compliance complexity and system change costs while preserving US regulatory relief.56
Who loses — Non-EU issuers lose potential research coverage improvements from the exemption.

Finance industry urges soft-law approach over AI regulation

10 Sept 2020
Feedback on — EU proposal for mandatory requirements on artificial intelligence applications and systems.
Their ask — AFME supports a voluntary, principles-based approach rather than mandatory AI-specific regulation. They argue existing financial services rules already address AI risks through consumer protection, conduct requirements, and operational resilience frameworks. Any new requirements should be limited to genuinely high-risk applications not covered by existing sectoral regulation.1234
How it helps them — This would avoid duplicative compliance costs and preserve their competitive position globally.56
Who loses — Citizens lose stronger protections if financial services exempted from high-risk designation.78

Finance Industry Seeks Cross-Sectoral Data Sharing Framework

31 Jul 2020
Feedback on — EU legislative framework for governance of common European data spaces.
Their ask — The organization requests cross-sectoral data sharing rules including digital platforms, improved data portability for users, and API standardization. They emphasize that mandatory sharing requirements should apply equally across sectors to maintain a level playing field.123
How it helps them — This would prevent them facing stricter data sharing obligations than digital platforms.45
Who loses — Digital platforms lose their current advantage in accessing financial data without reciprocal obligations.6

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

20 Jul 2020 · Update of the Covid-19 pandemic on European Capital markets and Capital Market Recovery Package

Finance industry urges nine-month delay for ESG suitability rules

6 Jul 2020
Feedback on — EU regulation requiring investment firms to integrate sustainability factors into client assessments.
Their ask — The Associations request a nine-month implementation delay after product governance rules take effect. They argue firms need time to update client profiles and source ESG data, citing significant data availability issues. They also seek clarity that ESG assessments should only apply to products with sustainable objectives.123
How it helps them — This would give them more time to upgrade IT systems and avoid clashing with other 2021 regulatory deadlines.45
Who loses — Investors seeking ESG products face continued uncertainty about which investments meet sustainability preferences.6

Finance industry urges nine-month delay for ESG rules

6 Jul 2020
Feedback on — EU directive requiring firms to integrate sustainability factors into product governance.
Their ask — AFME requests a nine-month implementation period after Member States transpose the directive, warning the current timeline could leave firms only one day to comply. They want flexibility to exclude products without sustainability elements and exemption from reviewing pre-existing instruments for ESG factors.1234
How it helps them — This would give them time to upgrade IT systems and avoid costly reviews of existing products.56
Who loses — Sustainable investors lose faster access to ESG information about existing financial products.7

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

9 Jun 2020 · Covid-19 economic recovery and Capital markets

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

29 May 2020 · digital finance

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

4 May 2020 · Capital Requirements Regulation

Financial industry seeks clearer GDPR rules for cross-border data flows

29 Apr 2020
Feedback on — Review of General Data Protection Regulation implementation, focusing on international transfers and cooperation.
Their ask — The organization requests broader review beyond international transfers and authority cooperation. They seek clarity on conflicts between GDPR and financial regulations, particularly for anti-money laundering data sharing. They want improved standard contractual clauses for processors transferring data to non-EU sub-processors.1234
How it helps them — This would reduce legal uncertainty and compliance complexity for cross-border financial operations.56
Who loses — Data subjects lose if clearer rules facilitate easier transfers without stronger safeguards.7

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

15 Apr 2020 · COVID-19 and Financial Markets, AFME coronavirus initiatives, CSDR buy-ins, MiFID, and CMU/securitisation.

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

3 Apr 2020 · COVID-19 and Financial Markets, MIFID Review, CMU - Securitisation and other AFME priorities

Finance Industry Pushes Public-Private Partnerships for Money Laundering Fight

11 Mar 2020
Feedback on — EU strategy to strengthen anti-money laundering and counter-terrorism financing regulations.
Their ask — The association wants stronger public-private partnerships for intelligence sharing and bank-to-bank information exchange. They advocate moving toward maximum harmonization through EU regulations rather than national directives, with uniform Know-Your-Customer requirements across member states.123
How it helps them — This would let banks operate with uniform policies and use resources more efficiently.4
Who loses — National regulators lose flexibility to impose stricter money laundering controls than EU baseline.5

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

17 Feb 2020 · Presentation of AFME’s position paper on Basel III

Financial markets association challenges auditor requirement removal for profit forecasts

21 Dec 2018
Feedback on — EU regulation on prospectus format, content, scrutiny and approval for securities offerings.
Their ask — AFME urges the Commission to reinstate the mandatory auditor report requirement for profit forecasts in prospectuses. They argue removing independent verification may result in less reliable forecasts and auditors becoming reluctant to provide comfort to issuers.123
How it helps them — This would preserve flexibility in disclosure while maintaining rigorous verification for marketing-focused forecasts.45
Who loses — The Commission loses simplified prospectus requirements and harmonized scrutiny across member states.6

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

20 Nov 2018 · Non-performing loans package

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

15 Nov 2018 · PRIIPs

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

12 Sept 2018 · Securitisation

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

12 Sept 2018 · Post-trade

Financial industry urges gradual taxonomy approach before regulatory changes

22 Aug 2018
Feedback on — EU regulation establishing criteria for determining which economic activities are environmentally sustainable.
Their ask — AFME requests the Commission develop the taxonomy before amending other financial regulations like MiFID II. They want clarity that the taxonomy applies to economic activities rather than specific products, and seek flexibility to incorporate existing market frameworks like the Green Bond Principles. They emphasize the need for regular updates and warn against overly prescriptive requirements.123
How it helps them — This would allow banks to avoid applying sustainability criteria across all offerings and maintain existing investment approaches.45
Who loses — Investors seeking broader sustainable strategies lose as narrow product scope limits diversification options.67

Financial Industry Urges EU Adopt Global LEI Over EUID

9 Jul 2018
Feedback on — EU proposal to digitize company law administrative processes and entity identification.
Their ask — AFME and ISDA request the Commission replace the proposed EUID with the Legal Entity Identifier (LEI) as the standard identifier for EU companies. They argue the LEI is already a global standard endorsed by the G20, used across EU financial regulations, and would avoid forcing companies to maintain multiple identifiers.123
How it helps them — This would eliminate duplicate compliance requirements for financial firms already using LEIs.45

Meeting with Paulina Dejmek Hack (Cabinet of President Jean-Claude Juncker)

6 Jul 2018 · Prudential Board meeting (on Banking Union and Capital Markets Union)

Finance industry urges delay on sustainable investment rules

21 Jun 2018
Feedback on — EU proposal requiring investment advisers to assess clients' sustainability preferences under MiFID II.
Their ask — AFME requests that changes to MiFID II suitability rules be delayed until after the EU taxonomy is established and refined. They argue the Commission's 18-month implementation timeline is too ambitious and would create inconsistent comparisons of sustainable investments.123
How it helps them — This would give them more time to adapt systems and avoid costly repapering exercises.45
Who loses — Retail investors lose faster access to standardized sustainability information when making investment decisions.6

Financial markets lobby warns EU NPL rules risk harming loan trading

8 Jun 2018
Feedback on — EU directive on credit servicers, purchasers and collateral recovery for non-performing loans.
Their ask — AFME requests narrower scope excluding performing loans and syndicated arrangements. They want the directive focused only on non-performing loans to avoid disrupting well-functioning markets. They argue the broad scope would impose unnecessary costs and reduce liquidity in performing loan markets.123
How it helps them — This would allow banks to avoid costly new disclosure rules for profitable loan sales.45
Who loses — Borrowers lose protections as buyer-beware principle reversal is rejected for performing loans.6

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

6 Jun 2018 · Cyber security, Fintech

Meeting with Julie Ruff (Cabinet of Commissioner Julian King)

6 Jun 2018 · Cybersecurity

Financial markets association urges flexibility on non-performing loan provisions

24 May 2018
Feedback on — Statutory prudential backstops to prevent under-provisioning of non-performing loans in banks.
Their ask — AFME opposes the Commission's Pillar 1 approach to non-performing loans, arguing it is inadequate for the heterogenous nature of NPLs. They advocate for a Pillar 2 approach that accounts for banks' specific NPL portfolios and economic environments. They also request alignment between the Commission's proposal and the ECB's guidance to avoid duplicative processes.123
How it helps them — This would reduce compliance costs and avoid operational burden from running duplicative processes.45
Who loses — SMEs and corporate clients face higher borrowing costs and reduced lending volumes.6

Financial industry urges deadline flexibility in shareholder rights rules

9 May 2018
Feedback on — EU regulation on shareholder identification and transmission of information for voting rights.
Their ask — AFME requests flexible 'without undue delay' language instead of same-day transmission requirements, and opposes extremely tight deadlines for information transfer. They seek alignment with existing market standards and opt-out provisions for shareholders not wishing to receive notifications.123
How it helps them — This would reduce operational complexity and allow time for manual processing requirements.45
Who loses — Shareholders lose faster notification of corporate events and voting opportunities.6

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

23 Mar 2018 · PRIIPs, Sustainable finance, ESAs review

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

16 Mar 2018 · LCR and LCR and Solvency II; securitisation

Finance Industry Urges Caution on European Safe Asset Plans

20 Feb 2018
Feedback on — EU framework for creating sovereign bond-backed securities as European safe assets.
Their ask — AFME requests further consultations before progressing the initiative, expressing concerns about market feasibility and unintended consequences. They argue essential criteria for success have not been met and warn the proposal could harm European government bond market liquidity.123
How it helps them — This would protect their members' profitable sovereign debt trading operations from disruption.45
Who loses — Proponents of Banking Union completion lose momentum toward breaking sovereign-bank doom loop.67

Financial Markets Group Backs EU Crowdfunding Framework

24 Nov 2017
Feedback on — European Commission proposal for EU-wide regulation of crowdfunding and peer-to-peer finance platforms.
Their ask — The association favours options creating an EU-wide framework with adequate oversight of platforms, a European single market for retail investors, and clearer rules using existing passporting regimes to enable cross-border growth.1234
How it helps them — This would help crowdfunding platforms scale cross-border and overcome current legal fragmentation barriers.56

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

14 Sept 2017 · CMU and Banking Union

Financial markets lobby opposes systematic internaliser rule changes

13 Jul 2017
Feedback on — European Commission proposal to tighten rules on systematic internaliser trading activities.
Their ask — AFME requests amendments to preserve broker-dealer flexibility and intra-group risk management. They argue the current drafting is too broad and could restrict firms from accessing liquidity for clients and managing risk internally.123
How it helps them — This would preserve their ability to manage risk and maintain profitable intra-group arrangements.45
Who loses — Market transparency suffers as firms maintain ability to bypass trading venue requirements.6

Meeting with Elina Melngaile (Cabinet of Vice-President Valdis Dombrovskis), Jan Ceyssens (Cabinet of Vice-President Valdis Dombrovskis) and

21 Jun 2017 · first part of the regulatory review, cross-Border regulatory coordination, cyber security, Brexit and its external impacts

Meeting with Laure Chapuis-Kombos (Cabinet of Vice-President Andrus Ansip)

7 Apr 2017 · Retail banking secor, analysis of the General Data protection regulation (GDPR)

Meeting with Michelle Sutton (Cabinet of First Vice-President Frans Timmermans)

7 Mar 2017 · Better Regulation, Capital Markets Union, Transparency

Meeting with Valdis Dombrovskis (Vice-President) and

7 Mar 2017 · Keynote speech at the Conference on "The Shortage of Risk Capital for Europe's High Growth"

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

3 Feb 2017 · Banking Package; ESA review

Meeting with Ioana Diaconescu (Cabinet of Commissioner Pierre Moscovici)

17 Nov 2016 · ‘CRD5’ package

Meeting with Paulina Dejmek Hack (Cabinet of President Jean-Claude Juncker)

9 Nov 2016 · financial services agenda

Meeting with Paulina Dejmek Hack (Cabinet of President Jean-Claude Juncker)

19 Oct 2016 · EU financial services regulation

Meeting with Bodo Lehmann (Digital Economy)

13 Oct 2016 · cybersecurity

Meeting with Bodo Lehmann (Digital Economy)

13 Oct 2016 · cybersecurity

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

22 Sept 2016 · Sustainable finance

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

20 Sept 2016 · Basel

Meeting with Keith Sequeira (Cabinet of Commissioner Carlos Moedas)

5 Jul 2016 · Finance and Innovation

Meeting with Mette Toftdal Grolleman (Cabinet of Commissioner Jonathan Hill)

18 Apr 2016 · Securitisation; Banking prudential issues;

Meeting with Paulina Dejmek Hack (Cabinet of President Jean-Claude Juncker)

27 Jan 2016 · Capital Markets Union

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

27 Jan 2016 · Investment plan

Meeting with Lee Foulger (Cabinet of Vice-President Valdis Dombrovskis)

11 Jan 2016 · Joint meeting/Markets in Financial Instruments Directive level2

Meeting with Lee Foulger (Cabinet of Vice-President Valdis Dombrovskis)

18 Sept 2015 · Securitisation

Meeting with Matthew Baldwin (Cabinet of Commissioner Jonathan Hill)

17 Sept 2015 · Financial Policy

Meeting with Lee Foulger (Cabinet of Vice-President Valdis Dombrovskis)

17 Jul 2015 · Capital Markets Union

Meeting with Lee Foulger (Cabinet of Vice-President Valdis Dombrovskis)

16 Apr 2015 · Markets in Financial Instruments Directive

Meeting with Lee Foulger (Cabinet of Vice-President Valdis Dombrovskis)

10 Apr 2015 · Markets in Financial Instruments Directive

Meeting with Mette Toftdal Grolleman (Cabinet of Commissioner Jonathan Hill)

27 Mar 2015 · Discussion on the study on the impact of NSFR on capital markets

Meeting with Valérie Herzberg (Cabinet of Vice-President Jyrki Katainen) and European Forum for Manufacturing

18 Mar 2015 · Event preparation

Meeting with Jonathan Hill (Commissioner)

27 Jan 2015 · Capital Markets Union

Meeting with Ioana Diaconescu (Cabinet of Commissioner Pierre Moscovici)

21 Jan 2015 · Capital Markets Union, Banking Union issues: exchange of views

Meeting with Paulina Dejmek Hack (Cabinet of President Jean-Claude Juncker)

19 Jan 2015 · Capital Markets Union

Meeting with Lee Foulger (Cabinet of Vice-President Valdis Dombrovskis)

16 Jan 2015 · Capital Markets Union

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

17 Dec 2014 · CMU

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

17 Dec 2014 · Capital markets union

Meeting with Chantal Hughes (Cabinet of Commissioner Jonathan Hill) and PwCIL

3 Dec 2014 · Bank structural reform