ESBG short paper on the bank crisis management and deposit insurance framework (CMDI)

Position Paper | Prudential, Supervision and Resolution

Month: October 2022


The Banking Union is one the most relevant EU policy over the last decade. The financial crisis in 2008 and its subsequent sovereign debt crisis in the euro zone have revealed weaknesses inherent in the functioning of the banking industry and demonstrated the need to coordinate the supervision and to shape a common framework in Europe.

Created in 2014, the Banking Union was a powerful response aiming to ensure that the European banks are able to withstand the upcoming crisis in the future without recourse to taxpayers’ money. The Banking Union is based on three pillars:
i) the Single Supervisory Mechanism (SSM) set up rules on capital requirements mainly from the implementation of Basel agreement and gave to the European Central Bank the responsibility to coordinate this supervision;
ii) the Single Resolution Mechanism (SRM) established a Single Resolution Board (SRB) and a Single Resolution Fund (SRF) in order to ensure the orderly resolution of failing banks, while minimising their impact on the real economy and on public finances;
iii) , the Deposit Guarantee Schemes (DGS) aim to protect depositors in the case where their banks fail, and their deposits are not available anymore.
These new uncertain times worsened due to the high inflation and the war in Ukraine legitimates the ongoing implementation of Basel IV rules in the EU regulation. Indeed, a well-capitalised banking sector contributes to reinforce the resilience of the European economy. As regards the two other pillars of the Banking Union, the European Commission has been mandated by the Eurogroup to bring forward a legislative proposal for a strengthened Crisis Management and Deposit Insurance (CMDI) framework in June.

Without a political agreement between the Member States, the Eurogroup decided to postpone the introduction of a European Deposit Insurance Scheme (EDIS) which was included in the initial workplan drafted by the Eurogroup President Pascal Donohoe. Against this background and before the publication of the legislative package postponed at the beginning 2023, the European Savings and Retail Banks Group wishes to reiterate its supports to the current CMDI review and calls in the meantime for an evolution of the framework, not a revolution. Read our paper below:




Remote coaching to prevent dormancy among low-income savers

Scale2Save Campaign

Micro savings, maximum impact.

Research findings from Uganda

This research was conducted by Scott Graham, Anahit Tevosyan and Nathaniel Mayende at FINCA International, together with Ester Agasha from the Makerere University Business School, Dr. Joeri Smits and Sally Yacoub. We wish to thank FINCA International and FINCA Uganda for their support throughout this project, especially James Onyutta, Ciprian Panturu, Alice Lubwama, Scovia Swabrah and Justine Nabawanuka. We are also grateful to the Scale2Save team, in particular Weselina Angelow, Anton Simanowitz, and Apphia Ndungu for their many contributions to this work, and to our partner, the Mastercard Foundation, whose sponsorship made it possible

One of the challenges of providing savings services to the unbanked is that many new customers fail to use the account beyond the initial deposit, a problem known as dormancy.

In our study, a low-cost coaching intervention produced significantly higher levels of account activity and use of banking agents, with stronger effects on women. The pattern of account usage reflects the role that formal savings plays in helping customers satisfy short- and medium-term cash needs. In qualitative interviews, women explained that coaching fostered a greater sense of trust and relationship with the bank, and that it encouraged them to set aside even small sums as a form of protection against an uncertain future.



ESBG welcomes EU Commission's legislative proposal on instant payments

BRUSSELS, 26 OCTOBER 2022. The European Savings and Retail Banking Group (ESBG) welcomes the European Commission’s legislative proposal on instant payments announced today. The ESBG hopes that the initiative will strengthen the efforts of savings and retail banks to make instant payments the new normal across the European Union.

Since its introduction, the ESBG has been supporting the development and roll out of instant payments, inter alia by encouraging its member banks to adhere on a voluntary basis to the European instant payments scheme (SCT Inst), one of the major building blocks of a future pan-European solution. Instant payments allow frictionless transfers within 10 seconds in all European countries and therefore support the ambition to strengthen the European sovereignty in the payments sector. However, the ESBG still considers that adherence should be measured in terms of number of accounts reached, rather than in terms of adhering banks and therefore stresses the importance of a more balanced approach in this respect. Nevertheless, we welcome that a differentiation has been made between banks within the euro area and banks within other EU member states when it comes to adhering to the scheme.

Fabrice Denèle, CEO BPCE Payment Services and Chair of the ESBG Payments Committee.

The ESBG especially welcomes the proposal’s attempt to streamline the approach to sanctions screening, for which it has been advocating as a key element to make instant payments effective while remaining safe.

“Relying on a daily client database screening, instead of forcing both the sending and the receiving bank to screen each and every cross-border transaction, will allow banks to offer pan-European innovative solutions while ensuring full compliance with AML/CTF rules and targeted financial sanctions regulations” said Fabrice Denèle, CEO BPCE Payment Services and Chair of the ESBG Payments Committee.

“I am very pleased to see that the suggestions put forward by the industry have been taken on board” he continued. “The ESBG was among the first associations to raise awareness on the topic to the political agenda and our regular talks with the European Central Bank have triggered the set-up of a Task Force on sanctions screening that in January 2022 delivered its report to policymakers. I am convinced that with this new approach the number of false positives will decrease drastically – hence increasing consumer trust”.

Diederik Bruggink, ESBG Head of Innovation and Payments.

“ESBG member banks were already between the early adaptors of instant payments in euro”, said the association’s Head of Innovation and Payments, Diederik Bruggink.

“The first cross-border instant payment in euro took place between two ESBG member banks, notably between CaixaBank and Erste Bank, and also the first transaction in the European Central Bank’s instant settlement system TIPS was between to ESBG member banks, BPCE and CaixaBank”, he added.

The ESBG also welcomes the focus of the proposal on consumer protection, a long standing priority for all its member banks. It especially supports the decision to leave the concrete implementation of services known as Confirmation of Payee to the market, which demonstrates full trust in the ability of the industry to find the best solutions based on the specific needs of each Member State.

Finally, in taking note about the Commission’s position on the charging principles, the ESBG highlights that a long term sustainable business model benefiting all stakeholders is key not only to ensure the success of instant payments, but also to foster their innovative potential in the ecosystem.

Press contact:

Leticia Lozano, Senior Communications Adviser
Tel. +32 2211 1196

Download press release

ESBG and EACB congratulate EU Commission’s Expert Group on its Open Finance report

BRUSSELS, 25 OCTOBER 2022. The European Savings and Retail Banking Group (ESBG) and the European Association of Co-operative Banks (EACB) congratulate the Expert Group on European financial data space of the European Commission on the finalisation of their Report on Open Finance, delivered yesterday to Commissioner Mairead McGuinness. The report provides an overview on the modalities for data sharing and reuse based on a specific number of illustrative use cases and describes the key components of an open finance ecosystem in the EU.

Juliana Pichler, Senior Manager for Group Regulatory Affairs & Data Governance at Raiffeisen Bank International

“Established in June 2021, the financial data space Expert Group provided advice and expertise to Directorate General for Financial Stability and Capital Markets Union (DG FISMA) in relation to the preparation of legislative proposals and policy initiatives to foster the establishment of a common financial data space in the EU. The EACB and ESBG were actively involved by working closely with their representatives within the Expert Group, namely: Juliana Pichler, Senior Manager for Group Regulatory Affairs & Data Governance at Raiffeisen Bank International; and Gilles Saint-Romain, Head of Digital European public affairs at Groupe BPCE.

Working with experts from different fields representing a broad range of stakeholders was an incredible learning experience” declared Juliana Pichler.  “This report is very balanced and reflects the diversity of views between financial market participants, the outcome should help the reader to understand what is at stake and to make its own opinion.”

Gilles Saint-Romain, Head of Digital European public affairs at Groupe BPCE.

Gilles Saint-Romain stated: “We are convinced that a collaborative market driven approach allowing all EU economic actors to maximise innovation collectively is essential not only to have strong European market players in the lead of digital finance but also to bring more benefits to European customers”.

The ESBG and EACB believe that, for a data-driven economy to be successful, consumer protection and trust are the first prerequisite. A possible legal framework must avoid repeating the PSD2 model and instead be based on principles of mutual benefits, creating incentives for all market participants to join. The principle ‘same activity, same risks, same supervision, same rules’ should apply to all actors. This alone ensures a level playing field and a high level of consumer protection.

Building on the Report, the ESBG, EACB, and their members look forward to continuing the dialogue on open finance with the European Commission.


Press contact:

Leticia Lozano, Senior Communications Adviser
Tel. +32 2211 1196

Download press release

Applying a Gender Lens to Digital Transformation in Africa

Scale2Save Campaign

Micro savings, maximum impact.

Financial Inclusion Week (FIW) is an annual gathering of the global community working to advance inclusive finance. It is a forum for exchanging ideas, research, and perspectives from around the world. The community-driven agenda covers the most pressing topics, helping to inform and advise all of our efforts to advance inclusive finance. The Center for Financial Inclusion convenes FIW each year and invites partner organizations to showcase work, help set the global agenda for the year ahead, engage with the community, and more.

About the Session
Digitalization is among the most powerful forces driving change in the financial services industry in Africa, as elsewhere. Widespread use of mobile technology is driving digital access on the continent, which now has more mobile subscribers than the United States or Europe. But digital transformation goes beyond mobile and works for some customers more than for others.

This session will showcase how three FSPs from the Scale2Save Program in Kenya, Uganda and Nigeria have approached digitization to sharpen their competitive edge. We will apply a gender lens to the outcomes of their outreach strategies to highlight enabling and challenging factors for female customers:

KPOSB from Kenya will showcase how their digital group product supports rural savings groups in their financial management and how a digital ‘bank in a bag’ contributes to getting individual group members and grant recipients formally banked.
In Uganda instant signup features offered by Centenary Bank through peer-to-peer digital links are meant to attract women but for some shared agent channels really make a difference.
For LAPO Microfinance Bank in Nigeria, newly established agents opened up opportunities for some female micro-merchants, but non-digital field officers turned out to be the real sales force.
Taking the different experiences into account, the session will also discuss the need for a more segmented approach to tackle the digital gap for women and how better data and skillset building will improve inclusion for different groups of women



Savings can make all the difference

Savings can make all the difference

World Savings Day 2022

Established on 31 October 1924 by the WSBI founding fathers as the ‘World Thrift Day’, the World Savings Day has been marked ever since.

This year, as in the past, WSBI launched an awareness raising campaign, much in harmony with similar actions conducted by saving banks across the world. All these efforts have the same goal: to encourage people to save for ‘a rainy day’. The central piece of the campaign is an animated silent video with a simple but powerful message to raise awareness on how ‘Savings can make all the difference’ in times of need. In other words, how savings play a key role to build financial resilience and be prepared to face difficult times in the future.

Ahorrar puede marcar la diferencia

Día Mundial del Ahorro 2022

Establecido el 31 de octubre de 1924 por los fundadores del Instituto Mundial de Cajas de Ahorro y de Bancos Minoristas (WSBI, por sus siglas en inglés), el Día Mundial del Ahorro se conmemora desde entonces año con año en la misma fecha.

En esta ocasión, el WSBI lanzó su tradicional campana, en armonía con otras numerosas acciones que los bancos minoritas y cajas de ahorro llevan a cabo para concientizar a la población sobre la importancia de ahorrar para un futuro ‘día lluvioso’. La pieza central es un video mudo animado con un mensaje simple pero poderoso: Ahorrar puede marcar la diferencia.

L’épargne peut faire toute la différence

Journée mondiale de l'épargne

Etabli le 31 octobre 1924 par les pères fondateurs de WSBI, la Journée mondiale de l’épargne est célébrée depuis son instauration.

Cette année, comme par le passé, WSBI a lancé une campagne de sensibilisation, en harmonie avec des actions similaires menées par les caisses d’épargne à travers le monde. Tous ces efforts ont le même objectif : encourager les gens à épargner en prévision des mauvais jours.

WSBI présente une campagne visant à sensibiliser sur la façon dont l’épargne peut faire toute la différence en cas de besoin. En d’autres termes, comment l’épargne peut jouer un rôle clé pour renforcer la résilience financière et se préparer à affronter des moments difficiles à l’avenir. Comme l’indique notre slogan de cette année : L’épargne peut faire toute la différence.

Le point central de la campagne est une vidéo muette animée destiné à un public international.

Financial Education: A high priority

ESBG organises regular events promoting financial education, including the global World Savings Day on 31 October each year, as well as sponsor the European Stock Market Learning initiative for youths to simulate investing in the Frankfurt Stock Exchange and learn how to invest wisely.
ESBG works to ensure that financial education is discussed at the EU level and included in EU legislative texts to ensure credit providers are required to ensure their customers understand the product which they are buying, and any associated risks.

World Savings Day 2022


Financial education is another high priority topic in ESBG. Members have long-running mandates to provide financial education not just to our members, but also to the communities in which they serve.

ESBG keeps a close eye on prudential treatment of crypto assets

On 30 September 2022, ESBG responded to the second public consultation of the Basel Committee on Banking Supervision (BCBS) on the prudential treatment of banks' crypto asset exposures, which is built on the proposals in the first consultation issued in June 2021.

The basic structure of the proposal in the first consultation is maintained, with crypto assets divided into two broad groups: Group 1 includes those that are eligible for treatment under the existing Basel Framework with some modifications. Group 2, on the other hand, includes unbacked crypto asset and stable coins with ineffective stabilisation mechanisms, which are subject to a new conservative prudential treatment.

In the response to the second consultation in 2022, we advocated for the removal of the technological risk add-on from the proposed prudential framework.

The first reason for this would be the principle of technological neutrality. The regulation should focus on regulating the services but not the applicable technology in order not to prevent the adoption of a specific technology and to neither prefer nor prejudice a specific business model or service provider. Secondly, technological risk already exists in all asset classes. If persistent technological risks are detected, the supervisor could require actions for their mitigation or apply a Pillar 2 Requirement (P2R) surcharge. Finally, a common surcharge of capital would reduce institutions’ incentives to mitigate inherent risk.


OCTOBER 2022 | TOPICS: Prudential, Supervision and Resolution | Public Consultation | Crypto Assests | Basel Framework | Technology Neutrality

Joint letter to Commissioner McGuinness on the EFRAG consultation regarding its first set of draft ESRSs

Month: October 2022


On 27 September, the ESBG, together with the European Banking Federation (EBF), the European Association of Co-operative Banks (EACB), Insurance Europe, Accountancy Europe, Business Europe and European Issuers, has submitted a joint industry letter to Commissioner Mairead McGuinness regarding the European Financial Reporting Advisory Group (EFRAG) public consultation on its first set of draft European Sustainability Reporting Standards (ESRS).

In the letter, ESBG strongly emphasized the necessity to phase-in the submission of the disclosure requirements from EFRAG to the Commission. In this respect, it is considered that EFRAG should deliver a limited set of crucial ESRS by November 2022. After this, EFRAG and the Commission should agree on a detailed plan to deliver the rest of the first set of standards and all the other deliverables required by the Corporate Sustainability Reporting Directive (CSRD). All these will constitute the minimum requirements to be delivered within the pre-set deadlines by the Commission.

Download the Joint Letter