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>> WSBI Innovation and Digitisation Hub | >>EU Fintech Action Plan
Updated: October 2019
ESBG calls for a deepening of the Digital Single Market and the FinTech Action Plan and is in
favour of a continued industry dialogue in the next mandate period of the EU institutional bodies.
Policy responses relating to digitalisation and innovation in financial services should keep pace
with the evolution of financial technology. Therefore, a constant dialogue between policymakers
and savings and retail banks would be beneficial.
It is important to use the term FinTech correctly: FinTech products and services can be provided
by either financial institutions, such as savings and retail banks, or new entities. Considering
FinTech companies as different types of firms can lead to misjudgements when defining a
regulatory framework to FinTech activities. Applying the term “FinTech” in the sense of “startups”, can be misperceiving and limiting since banks and other institutions also invest heavily in
digitalisation and new technologies. “FinTech” should thus be understood as “technology enabled
innovation in all financial services” where banks are considered a central actor and partner for
establishment of both a strong FinTech framework and a true Digital Single Market. Therefore, it
is of utmost importance to develop a strong framework through the application of an appropriate
definition creating a level playing field in a technology neutral ecosystem.
ESBG advocates for the following high-level principles to create a regulatory and policy framework
that promotes successful innovation and digitalisation of the European economy:
A level playing field between stakeholders, and the principle of “same business – same
risk, same rules and supervision” should be respected in every policy debate and regulatory
framework. Including a holistic and horizontal approach towards the data economy, where
access to data and data sharing are seen in a broader context beyond financial services.
Technology neutrality needs to be a core principle as it should be the entity, the service and/or
the product that are regulated and not the technology.
Consumer protection, cybersecurity and competition should be at the forefront of
A level playing field across regulation and Member States should also be ensured to
prevent barriers to innovation and disparity in technological speed between countries.
Consistency is essential in legal application between member states and horizontal
communication between supervisors (both geographically and across areas of responsibility).
Finally, digital skills need to be fostered to prevent digital exclusion, heighten data awareness
and consumer protection.