On 15 September 2023, the EACB submitted its response to the call for evidence (CfE) of the European Securities and Markets Authority (ESMA) on the integration of sustainability preferences in the suitability assessment and product governance arrangements. Considering that such requirements directly impact the distribution services provided to clients of co-operative banks, our members and their clients are directly impacted by the “sustainability preferences” regime under MiFID II.
In general, the EACB would like to point out that the regulatory requirements are too granular and too complex from the perspective of clients and our co-operative banking members. Indeed, the EACB takes a critical view of ESMA's possible considerations on further interpretations (see paragraph 8 of Section 2 ‘Background’ of the CfE). This is especially considering that the EU goal of encouraging clients to increase their investment in financial instruments that take sustainability factors into account - which is also supported by our co-operative banking members - would rather be made more difficult.
For more details, please see our responses to the CfE in our position paper.