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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Financial Education: A high priority


1 MinutesOctober 11, 2022

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

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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.

European Stock Market Learning Website

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.

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

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

Audience

October 5, 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

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ESBG Event

Audience

25 OCTOBER

HYBRID EVENT

ASK FOR THE RECORD OF THE EVENT

constantin.vicol@wsbi-esbg.org

REGISTRATIONS

Promoting financial education among women and highlighting the need to focus a few more efforts in improving female financial literacy. This is the aim of the upcoming ESBG event “My World, My Knowledge, My Future: A Female Approach To Financial Education”.

Studies show that women are less likely to be financially literate than men – especially when it comes to investing. Men are statistically more likely to take risks, but also research their activities and understand what they are doing. A basis in financial education is key to our future success in saving, investing, and growing wealth in a safe environment – calculating the risk and understanding what could go wrong, or right.
Empowering consumers – in particular women, who are less engaged than men – with the knowledge to make sound financial decisions and build a better future is important in an era of low savings rates, pandemic recovery and an ever-changing digital world. Every day we find new challenges and face new risks, and we need to be armed with up-to-date information and simple knowledge how to navigate through the financial world.

Join us and be part of a pivotal debate on topics like :

• How can financial institutions raise awareness among women of the risks and responsibilities when investing?
• What can school curricula do to engage more girls in money topics?
• Where can financial institutions improve their financial education plans to appeal to a female audience?
• What can policy makers do to provide support when targeting this group?

SPEAKERS & PANELLISTS

Mairead McGuinness

EU Commissioner for Financial Services and
Capital Markets Union

Keynote Speaker

Petra Hielkema

Chairperson of the European Insurance and
Occupational Pensions Authority (EIOPA) 

Panellist

Dominique Goursolle Nouhaud

President ESBG and
National Federation of Savings Banks

Keynote Speaker

Verena Ross

Chairperson, European Securities and
Markets Autorithy ( ESMA)

Keynote Speaker


Ellen Bramness Arvidsson

Executive Director, Finance Norway

Panellist

Magdalena Brier

Chief Executive Officer, Profuturo

Panellist


Ann Cairns

Executive Vice Chair
Mastercard

Panellist

Gabriele Semmelrock-Werzer

President, Austrian Savings Banks Association

Panellist


Karolin Schriever

Executive Board Member
DSGV

Panellist

Prof. Dr. Bettina Fuhrmann

Vienna University of Economics and Business

Panellist


Weselina Angelow

Programme Director on
Scale2Save

Speaker

Michelle Schonenberger

Advisor at European Savings and Retail Banking Group – ESBG

Speaker


Jacki Davis

Moderator


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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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ESBG response to the EFRAG consultation on its first set of draft ESRSs calls to ensure levelled global playing field

ESBG submitted its response to the European Financial Reporting Advisory Group (EFRAG) public consultation on the first set of Draft EU Sustainability Reporting Standards (ESRSs) on 4 August. The consultation comes in response the European Commission’s proposal for a Corporate Sustainability Reporting Directive (CSRD) which envisages the adoption of EU Sustainability Reporting Standards (ESRSs). As part of this, the Commission mandated EFRAG to provide technical advice in the form of draft sustainability reporting standards.

In its response, ESBG highlighted the need for consistency between the International Sustainability Standards (ISSB) sustainability disclosures and the EFRAG ESRSs in order to ensure a levelled global playing field. Moreover, ESBG emphasises the lack of proportionality with respect to disclosure requirements, specifically for smaller/unlisted companies and proposes the provision of certain reporting requirements being made optional.

With respect to implementation challenges, ESBG considers that the data availability issue is the most critical challenge for financial institutions. Taking into consideration the above, ESBG proposed two phase-in solutions that are mutually complementary: i) first year reporting on own operations and gradual reporting on information from the value chain and ii) prioritisation of climate topics and gradual consideration of other environmental, social and governance topics.

Furthermore, we believe that there is not enough guidance in the exposure drafts with respect to the application of the double materiality principle (the requirements for companies to disclose not only the risks that affect, but also their impacts on society and on the environment). In this sense, this concept needs to be clarified and more guidance is needed in relation to specific sectors in due time.

ESBG stresses the limitation on disclosing value chain information for companies. We consider it is difficult to obtain information from companies that are not under the control of the institution (e.g. associate companies). We propose that a phase-in period of 2 years must be granted to financial undertakings to allow them to adapt their processes to collect the necessary information from their value chain.

As a next step, ESBG will evaluate if there is interest from members in submitting input into the up-coming EFRAG consultations on SME specific standards as well as on sector specific standards (EFRAG consultations are expected to be published in 2023).

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EU Taxonomy minimum safeguards: Criteria for the application of external checks should be further defined

ESBG submitted its final response to the Platform for Sustainable Finance (PSF) consultation on its draft report on minimum safeguards (MS) on 6 September. In its response, ESBG highlights that assessing whether a company complies with the due diligence processes should, other than relying on external checks as only possibility, be demonstrated by: i) proving that the applicable national legislation provides for sufficient guarantees concerning the specific topic; ii) self-declarations made by the client concerning the specific topic.

ESBG submitted its final response to the Platform for Sustainable Finance (PSF) consultation on its draft report on minimum safeguards (MS) on 6 September.

The report is intended to provide advice on the application of the minimum safeguards which bring a social and governance component to the EU Taxonomy. The report looks at human rights including workers’ rights and consumers´ rights, bribery/corruption, taxation and fair competition as core substantive topics for which compliance with minimum safeguards has to be defined. The draft report proposes a two-pronged approach for identifying non-compliance with MS, namely one related to adequate due diligence processes implemented in companies (internal checks) and the other related to the actual outcome of these processes or the company’s performance (external checks).

In its response, ESBG highlights that assessing whether a company complies with the due diligence processes should, other than relying on external checks as only possibility, be demonstrated by: i) proving that the applicable national legislation provides for sufficient guarantees concerning the specific topic; ii) self-declarations made by the client concerning the specific topic.

Moreover, ESBG emphasises that gravity thresholds for non-compliance should be defined, so that not every minor violation (e.g. of taxation or work laws) leads to the establishment of an external check.

Furthermore, when assessing compliance with MS, the report recommends that the focus should be on assessing the human rights due diligence processes of a company, rather than on controversy checks e.g. media coverage (currently employed by ESG ratings agencies), as it is considered that the latter is based on value judgement and is sometimes difficult to justify. ESBG believes that the administrative cost derived from direct analysis of due diligence processes would be too burdensome for institutions and emphasizes that they should rely on ESG ratings agencies in order to not impair financial activity.

Finally, ESBG calls for further clarifications on the level of application of MS in particular cases, e.g. an exposure to a company active in sectors that by definition do not fulfil the minimum safeguards to be taxonomy-eligible or -aligned, even if the specific transaction finances activities that fulfil all requirements.

As a next step, the Platform will analyse the feedback received and prepare the final report. ESBG will continue to monitor this very important topic, with the possibility to get involved at a later stage.

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