Call for clarification on the Artificial Intelligence Liability Directive

On 28 September, the European Commission published its proposal for the Artificial Intelligence Liability Directive which  complements and modernises the EU civil liability framework by introducing for the first time rules specific to damages caused by AI systems. 

The purpose is to lay down uniform rules in case of damages caused by AI systems and to establish broader protection for victims. The Directive is applicable to both individuals and businesses. The new rules will, for instance, make it easier to obtain compensation if someone has been discriminated against in a recruitment process involving AI technology.

It is proposed that five years after the entry into force of the AI Liability Directive, the Commission will assess the need for no-fault liability rules for AI-related claims if necessary.

Consequently, on 3 October, the Commission enabled relevant stakeholders to provide feedback on the proposed AI Liability Directive. All feedback to be received will be summarised by the Commission and presented to the Parliament and Council with the aim of feeding into the legislative debate.

As part of its mandate, ESBG replied to the Commission’s call for feedback on 2 December. In its response, ESBG supports the protection of consumers as well as adapting liability rules to the digital age, thereby setting out a framework for excellence and trust in AI.

However, ESBG understands from the proposed Directive that the presumption of a causal link in the case of fault is mainly a matter of “non-compliance of due diligence duties”. In this context, ESBG calls for clarification on what could be considered as non-compliance of due diligence duties. In particular, ESBG questions whether the presence of bias or discrimination could be considered a noncompliance of due diligence duties. Furthermore, clarification is necessary on what tools are available to providers and users of AI systems to refute the causal link.

Finally, as the AILD is a directive, members stress the importance to take the cultural and legal differences between member states into account when implementing. Different application across member states can lead to regulatory arbitrage where firms choose where to be domiciled according to the member states legislative application. Therefore, the directive should be aligned with the Rome I Regulation and the Rome II Regulation regarding the conflict of laws on the law applicable to non-contractual obligations.

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Call for clear scope of applicability of the Cyber Resilience Act

On 14 November, ESBG submitted its input to the European Commission’s call for feedback on the proposed Cyber Resilience Act, which was published in September. All feedback received will be summarised by the Commission and presented to the European Parliament and Council with the aim of feeding into the legislative debate.

On 15 September, the Commission published a proposal for a Cyber Resilience Act, which aims to protect consumers and businesses from products with inadequate security features. The Cyber Resilience Act introduces mandatory cybersecurity requirements for products with digital elements. It will ensure that digital products, such as wireless and wired products and software, are more secure for consumers across the EU. In addition to increasing the responsibility of manufacturers by obliging them to provide security support and software updates to address identified vulnerabilities, it will enable consumers to have sufficient information about the cybersecurity of the products they buy and use.

In the position paper, ESBG members welcome the Commission proposal and support the goal of only having secure software on the internal market. However, members believe that the Cyber Resilience Act leaves too much room for interpretation regarding its scope of applicability and therefore proposes that the Commission should make a clear scope-statement that would dissolve any uncertainty whether the software developed, operated, or marketed by financial institutions is in scope of this Act.

In addition, there are vertical initiatives that already regulate the cyber-resilience of hardware and software products used by certain sectors. This is the case of the Digital Operational Resilience Act (DORA) for the financial sector, a regulatory framework specifically designed and developed to ensure the digital operational resilience of the financial sector. Extending the scope of the Cyber Resilience Act to products manufactured by credit institutions may place additional burdens onto banks, on top of the already existing tight regulatory corset.

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Application of CGAP Customer Outcomes Framework in Uganda

Scale2Save Campaign

Micro savings, maximum impact.

The case study has applied the CGAP customer outcome indicator framework to test the impact of a new basic savings product positioned in the financial inclusion market and designed to encourage digital and/or remote account opening and transactions.

As a member of the WSBI and part of the Scale2Save program, a prominent retail bank volunteered this product for a case study.

The objective was to assess if the CGAP customer outcome indicator framework could be applied as a measuring tool to determine whether or not:

  • The design, positioning, performance and management of the product are working as intended;
  • The product is indeed improving the lives of target customers;
  • The bank is contributing to Uganda’s Financial Inclusion goals.

The CGAP customer outcomes indicators are generated from supply-side data and can be used internally by providers to measure their levels of customer-centricity. The ultimate objective, however, is for the jurisdiction’s authorities to have a quantifiable, comparable and consistent way to:

  • Detect which strategies, policies, practices, activities, products/services work for or against the customer;
  • Assess the impact of financial services at a market level for all customer segments; and
  • Determine if, and to what extent, providers in the sector are improving or detracting from national goals.

Since the focus of the Uganda case study is Financial Inclusion, focusing on savings, the jurisdiction-specific context was informed by the Bank of Uganda’s (BoU) Financial Inclusion Strategy, 2017. The five main strategic goals classified twenty gaps that the BoU had set out to address. These gaps were therefore used as the basis to map the global CGAP indicators to Uganda’s context.

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Scale2Save


Driving formal savings: What works for low-income women

Scale2Save Campaign

Micro savings, maximum impact.

Gender-inclusive products need to be designed with women’s needs in mind. Yet, the real question remains: What services do female customers value, prioritize and need? This learning paper aims to contribute to the growing evidence base around this topic, building on findings from a recent Scale2Save Customer Research.

While financial inclusion is expanding globally, the gender gap in access to financial services and products persists. To close the gender gap in financial inclusion and improve women’s meaningful use of financial services, there is a clear need for financial service providers to transition toward gender-aware strategies to build tailored products that create opportunities for women and lower barriers in their lives.

This paper found that by carefully crafting the customer experience for women, financial service providers considerably amplified the adoption of formal savings products, thus significantly expanding their customer base while also contributing to financial inclusion for a traditionally excluded customer segment, such as women.

Scale2Save is WSBI’s most recent programme for financial inclusion. It operated in six African countries.

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Scale2Save


African woman trader

The art of change

Scale2Save Campaign

Micro savings, maximum impact.

A practical approach to changing behaviors of financial service providers for more meaningful outreach to  low-income people.

During six years of implementation, the Scale2Save programme for financial inclusion gathered significant learning on institutional transformation. This publication explores the leanings from change management processes within the programme’s partner financial service providers.

Is change possible without changing our behaviours and habits? No. Change is not possible without changing the way we do things. And this requires close accompaniment, trust, and energy.

This paper analyses the processes Scale2Save implemented with LAPO Microfinance Bank in Nigeria,  ADVANS Côte d’Ivoire and BRAC Uganda Bank Limited.

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Scale2Save


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
leticialozano@wsbi-esbg.org
Tel. +32 2211 1196

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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
leticialozano@wsbi-esbg.org
Tel. +32 2211 1196

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Savings can make all the difference

Savings can make all the difference

Our World Savings Day campaign 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 hacer toda 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 hacer toda 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.

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Bank Asia Agent Banking: An Initiative to Reach the Unreached People for Better Financial Inclusion in Bangladesh

By Jakirul Islam, Senior Vice President in Bank Asia Limited

A number of banks have emerged with several technology driven innovative banking solutions to accelerate the national financial inclusion drive under prudent directives and support from the central bank (Bangladesh Bank) in Bangladesh. Bank Asia pioneered Agent Banking in 2014 for rural financial inclusion under the auspices of Bangladesh Bank. The bank is extending full range of banking services to the last mile citizens across the country.

Bank Asia’s Agent Banking with a vast network of more than 5000 agent outlets is reaching more than 5.1 million customers across 64 districts in Bangladesh. Bank Asia, alone represents more than 45% of total female customers in Agent Banking. It serves more than 2.0 million social safety net (SSN) beneficiaries through its Agent Banking.

Bank Asia’s agent outlets doubled over the past three years and it added more than 3.0 million customers over the past years of pandemic. It partnered with a2i to expand agent network through Union Digital Centre (UDC) and Bangladesh Post Office (BPO) under PPP model.

 

  • Bank Asia owns more than 26% of total agent banking outlets across the industry
  • 62% of its total agent banking customers are women.
  • The agent banking pioneer ranked top in customer acquisition. More than 90% customers of its agent banking fall under the rural geography.
  • Bank Asia is the only bank in Bangladesh who received grants from the Gates Foundation and MetLife Foundation to address the gender gap and financial health within the Low & moderate income group people.

Bank Asia’s unique ‘micro-branch ‘model to make the rural economy more vibrant

Bank Asia adopted its pioneering ‘micro-branch’ model in agent banking. Recently it expanded a sizeable network for its invention of ‘rural micro-merchant’ towards building a complete digital banking ecosystem for the rural economy. Agent banking, in contrast to other branchless banking, is largely driven by an exclusive specialized agent model. This could be due to initial investment requirements to set up an outlet: An outlet in agent banking is exclusive for Bank Asia and distinctly branded by various permanent marketing collaterals and point-of-sale materials (PoSMs). This requires 10-15 times higher investment than is needed for a typical mobile financial service (MFS) agent outlet. This model focuses on the three stakeholders bank itself, banking agents and customers.

In accordance with the central bank guidelines bank must maintain a minimum ratio of 3:1 for rural and urban agent banking outlets. Bank should prefer remote rural areas, chars, islands and other geographical areas with limited accessibility for establishing new agent banking outlets where there is no bank branch or agent point within  a proximity of one kilometre (with an exception of agent on UDC).

Bank Asia has 3 categories of agent outlets 1. Individual 2. Union Digital Centre (UDC) 3. E-Post centres by Bangladesh Post Office. Individual outlets are run by the individual entrepreneurs whereas UDCs and e-post centres are run by the designated entrepreneurs assigned by the Local Government Division (LGD) and Bangladesh Post Office.

Bank has defined a fees, charges and commission structure for the agent banking services. Agents earn from the commission set by the bank for each services category.

Key customer value proposition     

#1 providing banking access to the last-mile citizen

  • Bank Asia has an agent outlet network of more than 5000 across the country. Approximately 80% of them are located in rural areas. Bank Asia reports that more than 5.0 million clients transact through its agent outlet network, which accounts for approximately 34% of the total market share among 29 players. Unbanked customers can open bank accounts at the agent outlets and make peer-to-peer transfers to other bank accounts and pay their utility bills including passport fees and other variety of payments. Currently, a significant proportion of Bangladeshis still don’t have access to mobile phones, while agent banking offering bio-metric based digital banking services without mobile phones or any device ownership dependency at customers end.
  • The reliance on agent networks has its challenges as the provider must principally control quality and service. However, Bank Asia’s management strategy pivots on its careful selection of agents. They are primarily small business owners, fresh entrepreneurs and other institutional agents (like Union Digital Centre under a2i and e-post centers of Bangladesh Post Office) in rural areas. This allows Bank Asia to focus on their ability to manage their liquidity, community standing, trust, and operating hours. Bank Asia’s agents are also required to invest approximately BDT 0.5 million, which builds ownership and motivates them to keep customers happy.

 #2 Greater convenience, ease of use and cost effective

  • Rural customers can access Bank Asia agent outlets with greater ease when compared to a bank branch and other financial service outlets. Rural customers need to travel a maximum distance of no longer than two kilometres to reach a Bank Asia agent outlet, who provide the added advantage of operating beyond typical banking hours.
  • Compared to USSD or mobile phone based financial services where simple cash-in transactions can require seven to eight menu screens and entering two to three number sequences, Bank Asia agent banking to run on bio-metric fingerprint and facial recognition system without any dependence of mobile phones at user end.
  • Agent banking fees and charges are also affordable. It offers Free of Charge (FOC) cash withdrawal in compare to the alternatives in the market for OTC withdrawal from the mobile wallets which charges 1.80% (i.e. BDT20 per thousand as per market practice) of the withdrawal amount.

#3 Building trust in digital platforms

  • Cybersecurity is a burning issue across the regions and Bangladesh isn’t an exception. In 2017, country’s mobile payments industry faced a huge challenge with the rise of ‘digital hundi’ due to some anomalies in customer KYC. Given that customer trust of digital platforms, and in particular financial transactions is already low, incidents like this do not bode well. And payment solution providers, who are relatively new supply-side actors in the financial services space, cannot afford any reputational risks.
  • Bank Asia has invested in a multi-tier security system that is compliant with latest regulations and global standards for branchless banking. As an added security measure, Bank Asia uses bio-metric authentication through m-POS to confirm all transactions at an agent outlet. Customer KYC is also cross-checked with the Election Commission (EC) NID database. Bank Asia also introduced a robotics technology for inward remittance disbursement through its agent banking. This robotics technology has significantly minimized the human error and faster the process of disbursement.

#4 Capturing the mass-market; leveraging key use-cases

The last decade in Bangladesh has seen substantial progress in terms of key underlying drivers for digitising financial services, such as more reliable internet connectivity and increased smartphone penetration. The market is supported by favourable demographics, such as a relatively youthful population and increasing income levels, with the growing middle-class segment. However, while banking agent networks exist and are growing in Bangladesh.

A number of use cases which have differentiated Bank Asia Agent Banking from other alternatives in the market. Bank Asia has been focusing on the low and moderate income group people with a vision of greater financial inclusion through social safety net payments, inward remittance disbursement and loans for rural micro-entrepreneurs. The agent banking pioneer has already made noteworthy contribution through these use cases. Both inward remittance and loan disbursement through Agent Banking experienced a significant growth over the past two years of pandemic.

Lessons learned

  • Almost 50% customers are women in agent banking, however only around 2-3% agents are women. Female customers feel more comfortable to deal with a female agent.
  • Bank faces difficulties in finding suitable women agents who can meet the application criteria.
  • Agent outlets may act as center of excellence for providing complete digital banking services (payments, purchase, transfer, savings and credit) to the rural citizens of the country.
  • Public-private partnerships with Union Digital Centers by a2i under the ICT Division and Bangladesh Post Office helped to achieve some quick wins in customer acquisition and agent network expansion.
  • Partnerships with government entities facilitate more prospective businesses for the bank within digital space.
  • Agent banking is more cost-effective than any other digital financial services in Bangladesh. Higher transaction limit, cost and bio-metric security were the top three factors for users’ preference of agent banking over MFS.
  • The range of service offering from agent banking is greater than mobile financial services (MFS) channel. Agent banking extends full range of banking services to the last mile citizens whereas MFS do serve only digital payments without any savings and loans products.

Transitioning customers from OTC money transfer to financial wellness

In Bangladesh, the OTC trend is very similar to other Asian mobile/e-money markets, such as Pakistan, Myanmar, Vietnam and Cambodia, where OTC transactions made up the vast majority of transactions and served as a significant accelerator in each market.

However, we should keep it in our mind that MFS agents offering Cash in and Cash out (CICO), money transfer and bill payments services do not essentially create access to formal savings, credit and insurance for the last mile deprived people.

Bank Asia Agent Banking has been serving the rural citizens through a right set of value chain ‘Payments, Purchase, Transfer, Savings and Credits”

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New taxes on banks can affect economic growth

In the current context of high inflation and economic slowdown, and with the possibility of a recession in the horizon, it is more important than ever that savings and retail banks preserve their solvency. In this respect, the recent decision in some EU countries to impose new windfall taxes on the banking sector will further reduce the latter’s lending capacity to corporates and individuals.

BRUSSELS, 6 September 2022 – European savings and retail banks played a very relevant role during the Covid-19 pandemic, contributing to sustain businesses and families during lockdown periods and beyond, while closely cooperating with the authorities to avoid a credit crunch. They have also been publicly recognised in many jurisdictions as a relevant part of the solution to the post-pandemic economic recovery.

While the effects of the Covid-19 pandemics are still being felt, the EU economy is now facing a new crisis arising from supply chain shortages and the war in Ukraine, in which savings and retail banks continue to support their customers and economic activities in general. Even further, they are actively contributing to helping Next Generation EU funds reach the real economy, by providing additional funding through their extended network of branches covering the whole EU territory and through their expertise in risk assessment.

In the current context of high inflation and economic slowdown, and with the possibility of a recession in the horizon, it is more important than ever that savings and retail banks preserve their solvency. In this respect, the recent decision in some EU countries to impose new windfall taxes on the banking sector will further reduce the latter’s lending capacity to corporates and individuals.  These sectorial taxes are discriminatory and unjustified, as the expected increase in interest rates is unlikely to lead to extraordinary profits in the banking sector (they can even decrease if NPLs start to grow). In fact, marginally higher rates simply represent the return to a normal situation after many years of very low profitability due to the negative interest rate environment, which, in turn, has also negatively affected returns to shareholders. These new taxes have also placed financial institutions in a difficult situation with their supervisors, as the requirement of not transferring their cost to customers goes against EU legislation (“EBA Guidelines on Loan Origination” state that loan pricing should include all the costs supported by banks, including taxes).

A tax on the banking sector may also undermine the social work undertaken by savings and retail banks. Social responsibility is a core value of our members; towards their clients, employees, communities, and the environment. In this context, policy makers should carefully consider the negative impact of taxation on banking foundations which have historically been involved in investing in local communities, fighting poverty, and helping those who are the most vulnerable in society.

The EU financial sector already contributes significantly to EU national budgets under the current tax framework, and it is ESBG’s view that what is needed in these uncertain times is a strong and competitive retail banking sector in Europe that continues to fulfil its key function as credit provider to companies (especially SMEs) and families alike. Therefore, any measure that can weaken the recovery of the EU economy should be carefully considered.

Finally, we are also warning against the risk of a fragmented EU tax system and calling for more tax harmonisation across EU countries. Additional taxation at national level is detrimental to a level playing field by distorting competition within the EU internal market. A particular source of distortion arises from shadow banking activity (e.g.: hedge funds) and other non-bank financial players (e.g.: big techs or credit cooperatives) which generally remain outside the scope of windfall taxes applied to the banking sector. For this reason, we believe that uncoordinated national initiatives in the field of taxation should be avoided at all costs in order to provide the necessary conditions for a fair and even distribution of financial services to European citizens and companies; especially SMEs.

 

Press contact:

Leticia Lozano, Senior Communications Adviser

leticialozano@wsbi-esbg.org

Tel. +32 2211 1196

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