Comments

The German Banking Industry Committee welcomes the initiative of the European Banking Authority (EBA) to explore possible avenues for simplifying the existing credit risk framework. Efforts aimed at improving the efficiency, consistency and usability of the regulatory framework are generally appreciated. At the same time, the Committee notes that several elements outlined in the discussion paper may, in practice, lead to additional requirements, expectations or costs for institutions.

The German Banking Industry Committee welcomes the targeted consultation by the European Commission on the competitiveness of the EU banking sector. It should be emphasised that regulatory overload is seen as a central competitive disadvantage of European banks. In addition, regulation must serve the goal of mobilising capital, for example for transformation financing.

The vdp welcomes the initiative to revise the EU regulatory framework to strengthen the competitiveness of the EU banking sector. The focus should be on revising the Capital Requirements Regulation and Directive (CRR/CRD). This could help to avoid further increases in capital requirements in the coming years and reduce overregulation as well as complexity, without compromising the currently generally recognised strong financial stability of the banks.

The draft will not lead to broader application and greater market acceptance of the EU taxonomy with regard to property financing, environmental objective climate change mitigation and the activities 7.1, 7.2 and 7.7.

The German Banking Industry Committee generally welcomes the objectives proposed in the draft Guidelines for integrating ESG risks into supervisory stress testing and their cross-sectoral orientation.

The core proposal of the GBIC is to make the EU Taxonomy more practical and efficient, aiming to relieve both the financial sector and the real economy while promoting sustainability objectives.