ESBG responds to the European Commission consultation on the Retail Investment Strategy (RIS) legislative package

On 4 August 2023, the ESBG submitted its position paper on the Retail Investment Strategy (RIS) legislative package, answering to the European Commission’s consultation.

The ESBG provides its view regarding the more controversial issues, suggesting – where feasible – possible improvements regarding both the Omnibus Amending Directive and the Amending Regulation proposals.

With regard to the Amending Directive proposal, the decision to refrain from its original intention of proposing a complete ban on inducements is more than welcome, due to the “potential disruptive impact” it could cause as recognised by the Commission itself.

However, due to the huge number of additional tests, processes, obligations, requirements, organizational and IT implementations, the package departs from the goal of reducing information overload and making financial services more approachable for retail investors.

In addition, ESBG outlines the need, especially in the current economical context, to preserve a capital markets regulatory framework able to include and attract all kinds of retail investors.

More specifically, regarding to the MiFID framework, we express our concerns about the following topics.

  • Value for Money – The approach undertaken by the proposal with the consequent development of benchmarks fully mandated at Level 2 is too interventionist and would result in an indirect price fixing made with a complete lack of criteria and methodology set at Level 1.
  • Ban on inducements – The proposed Ban on inducements for non-advised transactions would: i) reduce competitiveness; ii) lead to higher costs for clients; iii) endanger the current multi-channel approach provided by the Savings Banks to their clients, and iv) jeopardise the development of digital media and open architecture models by financial services’ distributors.
  • Best interest test – The disproportionate focus placed on costs would lead retail clients to prioritise the “cheapest” product over others that could potentially offer them better value.
  • Review clause – The two-staged approach envisaged by the proposal is a too short-term of an approach, also considering the huge number of new procedures and requirements to be introduced and/or implemented.
  • Information and disclosure requirements – The approach undertaken would add complexity in contrast with the goal of the CMU to avoid the already massive information overload for clients.
  • Appropriateness test – The extension of this test would make non-advised transactions more complicated and time consuming to the detriment of potential investors who already complain about the current regulatory framework requirements.
  • Risk warnings – Due to the existing abundance of obligatory information, the additional warning requirements would lead to further lack of understanding for potential retail investors.
  • Transposition – The set deadline is too short considering the significant number of new requirements and changes, especially due to the circumstance that level 2 requirements will be enacted in parallel with national level 1 implementation.

With respect to the Amending Regulation proposal, ESBG appreciates many provisions able to address the existing weakness of the current regulatory framework. Nevertheless, some further improvements are suggested based on the recently issued ESAs report on PRIIPs review.

Full Position PaperExecutive Summary


Ines Scacchi

t.: +32 2 2111147
m.: +32 0490 42 65 99

WSBI-ESBG is looking for an Advisor – Payments and Digital Finance

About the Job

The WSBI-ESBG, the European Savings and Retail Banking Group and World Saving and Retail Banking Institute is located in Brussels and represents the interests of saving and retails banks and their associations worldwide :

We are currently looking for an (m/f/d)

Advisor – Payments and Digital Finance

The Advisor will complement a team of two advisors and will support the two savings and retail banking associations in the Department Payments, Digital Finance & Innovation at their Joint Office in Brussels. The Advisor is expected to monitor, analyse, advocate and represent members‘ interests on regulatory topics such as payment services, their digital transformation as well as banking innovation. One of the key topics at the moment is the digital euro. Expertise or affinity with payments and digital finance topics is a requirement.

WSBI-ESBG engages in fostering business exchange between savings and retail banks worldwide as and advocating for their interests at the heart of policy making on EU and international level.

Job description

  • Monitoring, analysing and researching policy and market developments on EU and international levels in the field of payment services, digital transformation and banking innovation (e.g. digital euro, instant payments, payment services) and updating members accordingly;
  • Drafting position papers based on the views of members;
  • Liaising with banking experts, public authorities and stakeholders on EU and global level;
  • Organising and advising working groups, such as committees and task forces;
  • Advocating for the members’ positions in roundtables, webinars and meetings and reporting from the discussions;
  • Represent members in various relevant industry fora.
  • Preparing high-quality and concisely articulated communications content for an internal and external audience, e.g. presentations, publications, websites and social media channels;
  • Identifying and liaising with relevant stakeholders.


  • Academic or professional background in a relevant field, e.g. EU affairs, law, economics, business, technology or political science;
  • Knowledge of banking, payments and respective digital developments;
  • Profound interest in public policy, EU affairs and affinity for retail financial services;
  • Strong skills in analysis, synthesis and organisation, combined with excellent written and verbal communication skills, preferably complemented by presentation skills;
  • High level of proactivity, self-initiative and interdisciplinary thinking;
  • Relevant computer and presentation skills, e.g. Word, PowerPoint, Excel;
  • Affinity for content and position development, event organisation as well as research;
  • Passion for payment services, digitalisation, innovation and financial technology;
  • Excellent command of English (oral and written, C1/C2 level); additional languages are an asset.

We Offer

  • Competitive remuneration with additional benefits (Group insurance, Health insurance, meal voucher, extra legal holidays);
  • A full-time and permanent position in one of the biggest EU stakeholder associations in the field of financial regulation;
  • A highly international environment with mutual esteem;
  • Working with international banking experts in a motivated and supportive team;
  • Networking with relevant stakeholders from the banking sector and public authorities;
  • The opportunity to specialise in EU digital policies and retail banking innovation;

Interested candidates are invited to send a C.V. accompanied by a covering letter by email to before 31 September 2023.

ESBG responds to the Commission’s call for evidence on the 2014-2020 EU consumer programme

On 22 June 2023, ESBG submitted its response to the consultation launched by the European Commission on the 2014-2020 EU consumer programme.

ESBG supports the objective of the EU Consumer Programme to strengthen and promote consumer protection in the EU. The aim of the eleven individual actions resulting from the programme was to ensure that consumers have access to accurate information, understand their rights and are protected when they buy or use goods and services in the EU. Educated consumers know their rights and are empowered to enforce them on their own.

However, ESBG sees the need for adjustments in order to establish a modern consumer protection fit for the digital age and matching European values. ESBG drew the Commission’s attention to the lack of common understanding of consumers and their need for protection within the EU. A uniform consumer model is absolutely crucial to assess the consumer program and essential for further development of the measures.

In its feedback, ESBG reminded that according to the well-established case law of the Court of Justice of the European Union (CJEU), the average consumer should be defined as “reasonably well-informed and reasonably observant and circumspect”. This means that consumers must be able to conclude contracts in a self-determined manner instead of being inundated with information.

In order to establish a modern consumer model, ESBG called the Commission for:

  • Consolidation and harmonization of information requirements (taking into account the digital distribution channels);
  • Reduction of the mandatory information to the essentials;
  • Strengthening of confidence in the consumer that he chooses for him or whether he already feels sufficiently informed or whether he or she needs even more comprehensive information;
  • Promotion of financial and digital literacy among consumers.

In addition, ESBG stressed that the scope of the statutory information obligations should reflect the significance of the respective legal transaction for the typical consumer.

Executive SummaryFull Position Paper

Marta Kajda
Legal Advisor
t.: +32 2 211 11 69

EU Spanish Presidency: WSBI-ESBG Spanish member, CECA’s contributions and proposals

EU Spanish Presidency: WSBI-ESBG Spanish member, CECA’s contributions and proposals

Last July 1st, Spain assumed the Presidency of the Council of the European Union.

This appointment represents a historic opportunity to make progress on all the challenges ahead, especially those regarding the green and digital transition, as well as the various ongoing regulatory issues. Therefore, in this period of profound changes, dialogue between different social groups, businesses, and public institutions is key to drive economic progress and social well-being.

In order to contribute to achieving this goal, WSBI-ESBG Spanish member CECA published a high-level paper entitled “Sector Positioning: Contributions and Proposals” This initiative aims to highlight the Savings and Retail Banking position towards the Spanish Presidency of the Council of the European Union.

CECA is dedicated to representing, defending, and promoting the interests of its member entities. To fulfil this purpose, CECA provides them with advice and support in their efforts to offer services that foster financial inclusion and access to credit. The work of CECA members is carried out with a sustainable approach, emphasizing social action and financial education.

Furthermore, CECA actively participates as a member in World Savings and Retail Banking Institute (WSBI) and the European Savings and Retail Banking Group (ESBG). These associations prioritize financing for families and SMEs, a model that aligns completely with CECA’s member entities. Currently, CECA represents approximately 40% of the Spanish financial system in terms of deposits. You can consult more information about them in the link:

Spanish Presidency of the Council of the European Union 2nd half of 2023 Positioning of the CECA sector: contributions and proposals

Read here

ESBG has recently submitted its response to the EBA consultation on its draft Guidelines on resubmission of historical data

ESBG has recently submitted its response to the EBA consultation on its draft Guidelines on resubmission of historical data under the EBA reporting framework.

The objective is to establish a standardized approach for financial institutions to resubmit historical data in case of errors or inaccuracies in their reports to competent and resolution authorities. The proposed guidelines suggest limiting the resubmission to specific historical periods, depending on the frequency of original reporting and affected reference dates.

The ultimate goal is to ensure consistent and high-quality data for use by regulatory authorities and the EBA.
ESBG’s response outlines the need for further reduction in the reporting burden faced by financial institutions. Additionally, it makes a series of proposals for improving the proportionality element as well as specific proposals based on thresholds to determine the materiality of resubmissions.

Furthermore, ESBG highlights the importance of coordination between the EBA, ECB and SRB on resubmission rules for supervisory, statistical, and resolution-related reporting and expresses concerns that the planned first application of the guidelines by 31 December 2023 might be premature.

EBA ConsultationESBG Response

Andreea Lungu
Advisor- Financial Reporting and Taxation
t.: +32 2 211 11 64

ESBG’s response to the Commission call for feedback on its proposal for the regulation on the transparency and integrity of ESG rating activities

On 3 August 2023, ESBG responded to the Commission call for feedback on its ESG ratings proposal. ESBG welcomes the objective to tackle greenwashing by overcoming current deficiencies in the ESG ratings market. Nevertheless, ESBG stresses that this should not lead to adverse impacts for financial undertakings, especially when it comes to disclosing financial information.


First of all, ESBG welcomes this consultation as well as the possibility given by the Commission to provide feedbacks on its proposal for the regulation on the transparency and integrity of ESG rating activities. ESBG would like to stress its commitment to sustainability and its support when it comes to fighting greenwashing.

Nonetheless, ESBG sees some shortcomings in the Commission’s proposal. Hence, ESBG would like to stress the that Every rating agency, regardless of whether the rating report is solicited or not, should send the report to the client/rated undertaking to allow him to review it, in case the client wishes to provide additional information and/or corrections, if necessary, in order to avoid any potential misinterpretation. From a practical perspective, it will mean that ESG rating providers should provide their draft Rating report to the rated undertaking upon request. The rated undertaking shall have the right to review and correct data if necessary.

On top of that, ESBG would like to stress that if ESG rating agencies want more information, beside what is publicly available, and that financial undertakings cannot deliver that information (for confidentiality reasons for instance), not delivering that information must not have a negative impact on the rating. In other words, one can fully understand that ESG rating agencies might need to consult other documents besides the non-financial report of undertakings to have a more comprehensive view of a particular element. However, it should not have a negative impact on the rating if certain (unaudited) information or documents cannot be provided due to e.g. confidentiality reasons

ESBG ResponseExecutive SummaryCommissions Consultation

Contact Person:
Adrien Boudet – Associate Advisor- Sustainable Finance
t.: +32 2 211 11 63