Simplification is key to boosting investments and ensuring EU competitiveness — a goal the EACB strongly supports. The EACB therefore welcomes the various regulatory simplification proposals included in the European Commission’s Work Programme 2025 and in the SIU strategy. The Retail Investment Strategy (RIS) must remain consistent with the SIU’s objectives of simplification, competitiveness, and increased retail investor participation in financial markets.
At present, the RIS proposals are not doing so. From the perspective of EU cooperative banks, it is crucial that the RIS be fully aligned with the SIU’s goals.
Against this background, we propose:
- Rethinking the value-for-money framework and delete rigid, cost-based benchmarks
- Abandoning the best interest test to prevent unintended favouring of low-cost, non-EU products
- Rejecting overlapping tests (e.g. inducement, quality enhancement)
- Preserving the current approach to non-advised transactions
- Broadening access to plain vanilla bonds under MiFID II exemptions
- Retaining MiFID quick fix changes for professional clients and eligible counterparties
- Avoiding additional information obligations that risk overwhelming clients
We therefore urge legislators to conduct a thorough reassessment of the RIS and deliver concrete and effective proposals that ensure simplification and support competitiveness.
Should these objectives not be met, we strongly recommend withdrawing the file.