Positions
SFC response to Commission's targeted consultation on banking sector competitiveness
April 2026
The Swiss Finance Council (SFC) has recently submitted its response to the European Commission’s targeted consultation on the competitiveness of the EU banking sector.
The banking sector has a crucial role in supporting economic growth – financing businesses, mobilising private savings, and channelling capital toward long-term investments – while bridging the gap between the high level of private savings and the financing needs of companies, infrastructure, and strategic transitions. To achieve these objectives and fully realise their benefits, the EU should adopt a comprehensive approach that mobilises private savings, strengthens capital markets, reduces regulatory fragmentation, and ensures an internationally consistent framework – while facilitating the efficient flow of capital and financial services both within the EU and with trusted third countries.
SFC Recommendations at a glance:
- Adjusting MiFID II client categorisation rules: Targeted MiFID II reforms would help mobilise the significant pool of private savings currently held in deposits by EU households. Tailoring access to a wider range of investment products for experienced retail clients would deepen capital markets and increase capital available to EU firms. This would directly strengthen the Savings and Investments Union (SIU) and accelerate the EU's green and digital transitions.
- Supporting the contribution of third-country banks to EU growth: Reducing barriers to cross-border financial services from trusted non-EU institutions would bring additional capital and expertise into the EU economy. A harmonised framework allowing qualified third-country banks to serve EU clients would ensure a level playing field while expanding access to high-quality financial services. This would help channel significant volumes of client assets towards EU strategic priorities.
- Reducing regulatory fragmentation within the EU: Gold-plating at national level and divergent supervisory practices impose duplicative processes and higher compliance costs on banks operating cross-border. Greater harmonisation and more convergent supervisory practices would enhance legal certainty and improve capital allocation across the Single Market. Limiting national discretion in implementation should remain a core priority.
- Simplifying the prudential framework: The EU prudential framework has grown excessively complex, with an expanding reliance on Level 2 measures substantially increasing the regulatory burden on banks. Streamlining reporting obligations and refocusing Level 2 measures on genuinely technical aspects would reduce costs while maintaining strong prudential safeguards.
- Ensuring international alignment and consistency: Divergent Basel III implementation across jurisdictions risks creating an uneven playing field and regulatory fragmentation. Targeted refinements – notably on unrated corporate exposures and the Fundamental Review of the Trading Book (FRTB) – deserve consideration at international level. Basel standards should remain the common minimum denominator across jurisdictions, ensuring prudential frameworks stay proportionate, coherent, and globally consistent.
- Introducing tax incentives for capital markets investment: Current tax frameworks do not sufficiently encourage households to channel savings into productive long-term investment. Targeted fiscal incentives – such as exemptions on investment income and simplified reporting – would increase market liquidity and support corporate growth. Existing financial transaction taxes (FTTs) should also be reconsidered, as they raise costs without delivering expected tax revenues.
- Providing proportionate requirements for smaller banks: Smaller banks face a disproportionately high regulatory burden relative to their size and risk profile. Requirements should be calibrated to the nature and scale of each institution, with simplified approaches to reporting, disclosure, and stress testing.
All other Positions

SFC recommendations on the legislative proposal to review the Sustainable Finance Disclosures Regulation (SFDR)
February 2026
The Swiss Finance Council (SFC) has recently shared its technical recommendations regarding the European Commission’s legislative proposal to revise the Sustainable Finance Disclosure Regulation (SFDR) with EU policymakers.

Joint Association Paper on the Review of the Securitisation Framework
November 2025
The Swiss Finance Council (SFC) published a position paper on the Review of the EU Securitisation Framework jointly with leading trade associations, based in the US, whose members are global financial institutions with a significant presence in, and commitment to, the EU.

Swiss Finance Council position on FiDA
September 2025
The Swiss Finance Council (SFC) supports the policy objectives of the European Commission’s proposal for a Framework for Financial Data Access (FiDA) to improve economic outcomes for both financial services customers and financial sector firms and the EU’s political priorities of simplification, competitiveness, and growth.

Joint Association Position on the National Transposition of Art. 21c CRD VI
September 2025
The Swiss Finance Council (SFC) published jointly with leading trade associations based in the US, the UK and Japan a position paper providing guidance to Member States on implementing the Branch Requirement under CRD VI.

SFC Response to the European Commission’s targeted consultation on the integration of EU Capital Markets
July 2025
Swiss Finance Council members include some of the largest global asset and wealth management firms, many of which have substantial activities and make substantial investments in the EU. Our members operate as investment product manufacturers, distributors, and advisors, serving EU clients from both within the EU and on a cross-border basis, and non-EU clients investing in the EU. Given that the EU and Swiss economies are closely interconnected, we have a shared interest in ensuring the international competitiveness of the European economy. Our members are therefore deeply committed to the EU’s goal of building an effective and open Savings and Investments Union (SIU) that helps capital flow to EU projects and businesses that are key to foster citizens’ wealth, while boosting EU economic growth and competitiveness.

Joint response to the EC Call for Evidence to inform the Impact Assessment ahead of the review of the Sustainable Finance Disclosures Regulation (SFDR)
June 2025
The Swiss Finance Council (SFC) and Bank Policy Institute (BPI) have jointly submitted a response to the European Commission’s Call for Evidence to inform the Impact Assessment ahead of the Sustainable Finance Disclosures Regulation (SFDR).

SFC response to EC targeted consultation on the functioning of the EU securitisation framework
December 2024
The EU securitisation market remains underdeveloped, limiting investment opportunities in EU financial instrument and constraining banks' ability to manage their balance sheets. The Swiss Finance Council (SFC) therefore supports the European Commission's intention to improve the functioning of the EU securitisation framework. In its response to the European Commissions’ consultation, the SFC emphasizes the need to adjust the prudential treatment and move towards a more principles-based approach to disclosure in order to unlock the potential of securitisation as a powerful financing tool.

SFC response to EC consultation on assessing the adequacy of macroprudential policies for non-bank financial intermediation (NBFI)
November 2024
The SFC has responded to the European Commission’s targeted consultation on assessing the adequacy of macroprudential policies for non-bank financial intermediation (NBFI).

SFC response on NBFI consultation
September 2024
The Swiss Finance Council has a strong interest in the targeted consultation on the effectiveness of the macroprudential framework for the Non-Bank Financial Intermediation (NBFI) sector. Swiss asset managers manufacture both Money Market Funds (MMFs) and Open-Ended Funds (OEFs) within the EU and manage and distribute them both within the EU and on a cross-border basis. Therefore, any changes to the EU macroprudential framework for MMFs and OEFs would have a direct impact on Swiss asset managers. More broadly, given the interconnectedness of EU and Swiss markets, there is need for continued international cooperation on the NBFI agenda.

SFC recommendations for the next EU legislative cycle
June 2024
Given that the EU and Swiss economies are closely interconnected, we have a shared interest in ensuring the international competitiveness of the European economy. Our members are therefore deeply committed to the EU’s goal of building an effective and open Capital Markets Union that helps capital flow to EU projects and business that are key for the transition towards a more sustainable and digital economy.

Response to the EBA’s Consultation on Draft Guidelines on the management of ESG risks under the Capital Requirements Directive (CRD 6)
April 2024
The Swiss Finance Council co-signed a response to the EBA’s Consultation on Draft Guidelines on the management of ESG risks under the Capital Requirements Directive (CRD 6)

SFC response to the ESMA consultation on reverse solicitation and classification of crypto assets as financial instruments under MiCA
April 2024
Swiss Finance Council response to ESMA consultation on draft guidelines on reverse solicitation under MiCA

Swiss Finance Council position on reduction of the settlement cycle to T+1
January 2024
The Swiss Finance Council has a strong interest in the discussion on shortening the settlement cycle to T+1 across equities, fixed income and ETFs in Europe because Swiss, EU and UK securities markets are closely interconnected and in the post-trade area apply the same principles and technical standards. This is a complex area that will require careful analysis and policy development to assist firms in managing the significant operational challenges that will stem from the transition.

Swiss Finance Council response to the European Commission’s consultation on the implementation of the Sustainable Finance Disclosure Regulation (SFDR)
December 2023
The Swiss Finance Council has an interest in the SFDR because our members operate as retail investment product manufacturers, distributors, and advisors, serving EU clients from both within the EU and on a cross-border basis.

Swiss Finance Council position paper on future of CMU
December 2023
The Swiss Finance Council welcomes the public reflection on the future of the EU Capital Markets Union (CMU) project. We believe that a particular focus should be given on measures that can bring more size into the EU capital market in the short and medium term and guide financing of the green transition.

Swiss Finance Council position paper on EU Financial Data Access Regulation
November 2023
The Swiss Finance Council believe that FIDA has the potential to unlock data sharing between wealth management firms, WealthTech firms and other service providers within the EU.

Swiss Finance Council position paper on EU Retail Investment Strategy
September 2023
The Swiss Finance Council has an interest in the EU Retail Investment Strategy because our members operate as both retail investment product manufacturers and distributors, serving EU clients from both within the EU and on a cross-border basis.

Joint association letter on CSDDD and transition plans
Joint association letter on CSDDD and transition plans – September 2023

Swiss Finance Council’s comments on draft ESRS Delegated Act
Swiss Finance Council’s comments on draft ESRS Delegated Act – July 2023

SFC position on Instant Credit Transfers in Euro - Amending the SEPA Regulation
SFC Position on Instant Credit Transfers in Euro : Amending the SEPA Regulation – May 2023

Joint amendments to the CSDDD
Amendments to the Corporate Sustainability Due Diligence Directive (CSDDD) proposal – November 2022

SFC Position on an EU Open Finance Framework
Open Finance Framework in the EU: For a broad, competitive, attractive and fair approach to data sharingl – October 2022

Joint association letter on CSDDD
Feedback on the proposed Corporate Sustainability Due Diligence Directive (CSDDD) – August 2022

Joint association letter on CSRD
Feedback on the proposed Corporate Sustainability Reporting Directive (CSRD) and related Article 8 Taxonomy disclosures - April 2022

SFC Position on Third Country Branches
CRD VI Commission proposal on Third Country Branches (TCB): Position on market access, booking, liquidity and authorisation requirements (Art 47 and 48 CRD VI) - April 2022

Joint Associations Letter on Third Country Branches
Feedback on the Publication of the European Commission's Draft Capital Requirements Directive VI (CRD VI) - March 2022

SFC Position on the Corporate Sustainability Reporting Directive (CSRD) proposal
Corporate Sustainability Reporting Directive (CSRD) proposal - December 2021

Joint letter on the treatment of incoming third country branches
Joint letter on the treatment of incoming third country branches - September 2021

SFC response to European Commission consultation
European Commission consultation on the draft EU Taxonomy Article 8 Delegated Act - June 2021

SFC response to European Commission consultation
European Commission Consultation on the Renewed Sustainable Finance Strategy - July 2020

Joint letter to Vice-President Dombrovskis
Joint letter to Vice-President Dombrovskis: “Investment Firm Regulation – third country firm regime" - November 2018

Joint letter to EU Finance Ministers
Joint letter to EU Finance Ministers in response to the proposal for an EU Digital Services Tax - November 2018

SFC letter to Vice-President Dombrovskis
Public consultation on Fintech: a more competitive and innovative European financial sector - June 2017

SFC Response to European Commission Consultation
Call for evidence: EU regulatory framework for financial services - January 2016

European Commission Consultation on the impact of CRR/CRD4 on bank lending
SFC response to European Commission Consultation on the impact of CRR/CRD4 on bank lending

SFC response to European Commission Consultation on EMIR Review
SFC response to European Commission Consultation on EMIR Review

SFC response to European Commission Green Paper on Capital Markets Union
SFC response to European Commission Green Paper on Capital Markets Union

SFC response to IOSCO Consultation on Cross-Border Regulation
SFC response to IOSCO Consultation on Cross-Border Regulation
