Position papers

  • EAPB response to call for evidence GDPR

    8 February 2024

    The GDPR establishes a consistent legal framework throughout the EU, ensuring a high standard of data protection, which is generally deemed successful in the banking sector. However, it was noted by our members that ensuring GDPR compliance presents significant challenges for medium-sized and small companies, lacking the financial means and organizational capacity to employ all necessary experts, including DPOs and CISOs.

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  • EAPB call for adaptation of SME definition

    State aid, Sustainable finance 7 December 2023

    EAPB highly welcomes the SME relief package and in particular the announcement that, by the end of 2023, the EC will analyse the impact of high inflation and longer-run increases in productivity with a view to raising - when justified - the financial thresholds of the current SME definition and developing a harmonised definition for small mid-cap companies.

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  • EBIC letter on the Basel III implementation postponement

    Banking supervision 6 November 2023

    On 20 October, the European Banking Industry Committee (EBIC) submitted a joint letter to the co-legislators asking for a postponement of the Basel III implementation date in the European Union. EBIC strongly supports the ongoing legislative process aiming at finalizing the Banking Package. Given the substantial and comprehensive nature of the forthcoming legislative changes brought about by CRR III, a minimum of 18 months between the publication of CRR III rules in the Official Journal of the EU and the effective implementation date of the new rules will be necessary. Assuming CRR III publication in the Official Journal by end of 2023, EBIC suggests an initial application no earlier than 1 July 2025. Any postponement in the publication would require a further commensurate shift in the CRR III application.

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  • Social-Investment Framework-Advocacy-Paper-18th of September letter

    Banking supervision, Sustainable finance 9 October 2023

    Europe needs to mobilise capital for social investments. Sustainability has a social dimension, and consequently, Europe needs a framework to guide investments towards social housing, healthcare, education, and to ensure human rights in value chains. “We can and must reverse the trend that has seen investment in human capital, especially in health, education and affordable housing, stall in many regions and countries.” Report of the High-Level Task Force on Investing in Social Infrastructure in Europe 2018.

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  • EAPB Position paper on taxonomy and EU GBS

    Capital markets, Sustainable finance 22 September 2023

    EAPB members support the aim of the EU Taxonomy Regulation (“EU Taxonomy”) and EU Green Bond Standard (“EU GBS”), which is to direct more capital towards sustainable economic activities. Due to their specific business model, European promotional and public banks are well positioned to play a key role in a fair and social transition to a more sustainable society. This is recognized by the European Commission which stated that “National promotional banks play an important role in catalysing long-term finance” in policy areas including climate change.

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