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FinTech policy & banks: need for framework to boost innovation

FinTech policy & banks: need for framework to boost innovation



ESBG submits detailed response to Commission FinTech consultation

See full text of ESBG response >>

​​​​BRUSSELS, 15 June 2017 – Policymakers and legislators hold responsibility for creating an enabling environment for the deployment of technology and the harnessing of efficiency by market participants, according to a response by ESBG to the European Commission consultation on Fintech.

In the 29-page response, ESBG noted that innovative technologies such as Distributed Ledger Technology will require finely balanced support from policymakers and regulators in order to fully ensure their success, a support which should privilege either guidelines or standards and limit legislation to well defined areas.

ESBG Managing Director Chris De Noose said: “We made clear in our response that most policy measures aimed at boosting innovation will need to prioritise cybersecurity assurance for the market and the whole financial sector. Data protection and privacy-related issues, especially regarding the liability of new actors, such as robots, will also be central to the future of market integrity.”

​An enabling environment to innovate

In one of some 40 questions in the consultation, the EU savings and retail bank association adds that main role of policymakers should not be to issue constraining legislation – which would limit innovation to a narrow spectrum of opportunities – but to ensure that innovative solutions always fully comply with the existing regulatory framework, so that technological disruption in the financial sector does not produce negative effects for both consumers, investors and the market itself.

ESBG outlines what an enabling environment should look like. The association sees need for:

  • ​​ A stable, harmoniously transposed across the EU and coherent with other legislation, e-identity framework, which allows and motivates market participants to develop and operate convenient and secure e-identity solutions, interoperable where required with solutions deployed by national authorities, and interoperable across Member States.   

  • A much increased and then sustained effort to foster cybersecurity across all dimensions, prevention, detection, and remedy.   

  • A stable, harmoniously transposed across the EU and coherent with other legislation data protection framework (i.e.: the GDPR, with the necessary clarifications).  

  • A supervisory framework for cloud that provides legal certainty to the usage of cloud service providers cross border, and harmonization of the supervisory requirements applicable to banks in this respect.   

​Specific pieces of legislation

The comprehensive set of responses by ESBG includes a list of EU and/or Member State legislation and/or supervisory practices needing adjustment. They include areas like

E-identification and Anti-Money Laundering, where different national requirements still apply to notably the remote identification of customers, harmonization is required, to allow for digital onboarding including via video legitimation.  It also flags up rules on cybersecurity, especially on the prevention front, and regulatory areas like data, the cloud, alternative lending and investments, capital requirements and resolution, consumer protection, supervising and monitoring regulatory compliance and other CRD/CRR requirements.

De Noose concluded: “This consultation is important for our members because banks are heavy users of IT, and have been for decades. We try to make clear in our response that banks have always sought to implement technology for the benefit of customers. There is a need for policymakers to always keep this in mind.”


For more information, please contact:

​-          James Pieper on +32 2 211 11 92 or at; or

-          Dirk Smet on +32 2 211 11 90 or at



Note to editor:


ESBG – The Voice of Savings and Retail Banking in Europe

ESBG brings together nearly 1000 savings and retail banks in 20 European countries that believe in a common identity for European policies. ESBG members represent one of the largest European retail banking networks, comprising one-third of the retail banking market in Europe, with 190 million customers, more than 60,000 outlets, total assets of €7.1 trillion, non-bank deposits of €3.5 trillion, and non-bank loans of €3.7 trillion. ESBG members come together to agree on and promote common positions on relevant regulatory or supervisory matters. Learn more about ESBG at


>> See ESBG response



Digitalisation; Innovation; European Institutions