Positions
Joint association letter on CSRD
Feedback on the proposed Corporate Sustainability Reporting Directive (CSRD) and related Article 8 Taxonomy disclosures - April 2022
In view of the ongoing trilogue negotiations, the Swiss Finance Council has co-signed a letter on the Corporate Sustainability Reporting Directive (CSRD) outlining our proposal to mitigate the issues raised by the extraterritorial application of the CSRD. The ultimate objective of the proposal is to to build an effective international framework for sustainability reporting, which maximises the interoperability of local reporting standards, avoid fragmentation, promote greater transparency, consistency and comparability of disclosures.
Most importantly, our proposal would be beneficial for both EU and non-EU companies that are faced with the challenge of reporting on exposures for operations in third countries where sustainability information is unlikely to be available given the absence of legal requirements for companies outside the EU to disclose the same sustainability data as companies inside the EU. Among the others, we advocate for:
???? A transitional period during which the scope of sustainability reporting for both EU and non-EU companies could be limited to EU activities and EU exposures to companies that are subject to the CSRD and Taxonomy disclosure rules.
???? Allowing both EU and non-EU companies to comply with CSRD requirements by having the option of using the ISSB standards or other national standards based on those of the ISSB to report on non-EU exposures.
All other Positions
SFC response to EC consultation on AI in financial services
September 2024
The SFC has responded to the European Commission’s targeted consultation on Artificial Intelligence in the financial sector.
SFC response on NBFI consultation
September 2024
The Swiss Finance Council has a strong interest in the targeted consultation on the effectiveness of the macroprudential framework for the Non-Bank Financial Intermediation (NBFI) sector. Swiss asset managers manufacture both Money Market Funds (MMFs) and Open-Ended Funds (OEFs) within the EU and manage and distribute them both within the EU and on a cross-border basis. Therefore, any changes to the EU macroprudential framework for MMFs and OEFs would have a direct impact on Swiss asset managers. More broadly, given the interconnectedness of EU and Swiss markets, there is need for continued international cooperation on the NBFI agenda.
SFC recommendations for the next EU legislative cycle
June 2024
Given that the EU and Swiss economies are closely interconnected, we have a shared interest in ensuring the international competitiveness of the European economy. Our members are therefore deeply committed to the EU’s goal of building an effective and open Capital Markets Union that helps capital flow to EU projects and business that are key for the transition towards a more sustainable and digital economy.
Response to the EBA’s Consultation on Draft Guidelines on the management of ESG risks under the Capital Requirements Directive (CRD 6)
April 2024
The Swiss Finance Council co-signed a response to the EBA’s Consultation on Draft Guidelines on the management of ESG risks under the Capital Requirements Directive (CRD 6)
SFC response to the ESMA consultation on reverse solicitation and classification of crypto assets as financial instruments under MiCA
April 2024
Swiss Finance Council response to ESMA consultation on draft guidelines on reverse solicitation under MiCA
Swiss Finance Council position on reduction of the settlement cycle to T+1
January 2024
The Swiss Finance Council has a strong interest in the discussion on shortening the settlement cycle to T+1 across equities, fixed income and ETFs in Europe because Swiss, EU and UK securities markets are closely interconnected and in the post-trade area apply the same principles and technical standards. This is a complex area that will require careful analysis and policy development to assist firms in managing the significant operational challenges that will stem from the transition.
Swiss Finance Council response to the European Commission’s consultation on the implementation of the Sustainable Finance Disclosure Regulation (SFDR)
December 2023
The Swiss Finance Council has an interest in the SFDR because our members operate as retail investment product manufacturers, distributors, and advisors, serving EU clients from both within the EU and on a cross-border basis.
Swiss Finance Council position paper on future of CMU
December 2023
The Swiss Finance Council welcomes the public reflection on the future of the EU Capital Markets Union (CMU) project. We believe that a particular focus should be given on measures that can bring more size into the EU capital market in the short and medium term and guide financing of the green transition.
Swiss Finance Council position paper on EU Financial Data Access Regulation
November 2023
The Swiss Finance Council believe that FIDA has the potential to unlock data sharing between wealth management firms, WealthTech firms and other service providers within the EU.
Swiss Finance Council position paper on EU Retail Investment Strategy
September 2023
The Swiss Finance Council has an interest in the EU Retail Investment Strategy because our members operate as both retail investment product manufacturers and distributors, serving EU clients from both within the EU and on a cross-border basis.
Joint association letter on CSDDD and transition plans
Joint association letter on CSDDD and transition plans – September 2023
Swiss Finance Council’s comments on draft ESRS Delegated Act
Swiss Finance Council’s comments on draft ESRS Delegated Act – July 2023
SFC position on Instant Credit Transfers in Euro - Amending the SEPA Regulation
SFC Position on Instant Credit Transfers in Euro : Amending the SEPA Regulation – May 2023
Joint amendments to the CSDDD
Amendments to the Corporate Sustainability Due Diligence Directive (CSDDD) proposal – November 2022
SFC Position on an EU Open Finance Framework
Open Finance Framework in the EU: For a broad, competitive, attractive and fair approach to data sharingl – October 2022
Joint association letter on CSDDD
Feedback on the proposed Corporate Sustainability Due Diligence Directive (CSDDD) – August 2022
SFC Position on Third Country Branches
CRD VI Commission proposal on Third Country Branches (TCB): Position on market access, booking, liquidity and authorisation requirements (Art 47 and 48 CRD VI) - April 2022
Joint Associations Letter on Third Country Branches
Feedback on the Publication of the European Commission's Draft Capital Requirements Directive VI (CRD VI) - March 2022
SFC Position on the Corporate Sustainability Reporting Directive (CSRD) proposal
Corporate Sustainability Reporting Directive (CSRD) proposal - December 2021
Joint letter on the treatment of incoming third country branches
Joint letter on the treatment of incoming third country branches - September 2021
SFC response to European Commission consultation
European Commission consultation on the draft EU Taxonomy Article 8 Delegated Act - June 2021
SFC response to European Commission consultation
European Commission Consultation on the Renewed Sustainable Finance Strategy - July 2020
Joint letter to Vice-President Dombrovskis
Joint letter to Vice-President Dombrovskis: “Investment Firm Regulation – third country firm regime" - November 2018
Joint letter to EU Finance Ministers
Joint letter to EU Finance Ministers in response to the proposal for an EU Digital Services Tax - November 2018
SFC letter to Vice-President Dombrovskis
Public consultation on Fintech: a more competitive and innovative European financial sector - June 2017
SFC Response to European Commission Consultation
Call for evidence: EU regulatory framework for financial services - January 2016
European Commission Consultation on the impact of CRR/CRD4 on bank lending
SFC response to European Commission Consultation on the impact of CRR/CRD4 on bank lending
SFC response to European Commission Consultation on EMIR Review
SFC response to European Commission Consultation on EMIR Review
SFC response to European Commission Green Paper on Capital Markets Union
SFC response to European Commission Green Paper on Capital Markets Union
SFC response to IOSCO Consultation on Cross-Border Regulation
SFC response to IOSCO Consultation on Cross-Border Regulation