The ABBL calls for a more integrated and modernised EU capital markets

Key messages delivered to the European Commission

Simplify investor disclosures
The ABBL has long advocated for a thorough reform of the PRIIPs Key Information Document (KID) regime. Overlapping requirements with MiFID and SFDR have led to confusing, duplicative disclosures for retail investors. The response calls for a streamlined, digital-first and layered approach to ensure that product information is clear, accessible and focused on what truly matters for end users.

Reinforce proportionality
There is a continued need for greater proportionality in EU regulation, particularly in the trading and post-trading space. One-size-fits-all rules can place undue pressure on smaller institutions. A more proportionate framework would enable a broader range of actors to remain competitive while continuing to uphold investor protection.

Modernise market infrastructure through DLT
The ABBL supports turning the DLT Pilot Regime into a permanent, standalone framework. Recommendations include lifting quantitative thresholds, extending the regime to a wider range of financial instruments, and formally recognising tokenised money—such as CBDC, e-money and commercial bank tokens—for cash settlement.
The real challenge lies not in technology, but in modernising the legal and regulatory architecture that supports it.

Ensure supervisory consistency while maintaining proximity
The ABBL calls for better harmonisation of supervisory practices across EU Member States to ensure uniform implementation of EU rules. However, it also reaffirms the value of the current college-based model of national competent authorities (NCAs), which provides essential market proximity and day-to-day interaction.
A stronger role for ESMA in setting common standards and promoting convergence would be welcome, without moving towards full centralisation.

A shared ambition for stronger EU capital markets

Capital markets integration remains a critical objective for the EU’s long-term competitiveness. It will require sustained efforts to reduce fragmentation, support technological innovation, and deliver more consistent supervision—while respecting the diversity of local markets and actors.

The ABBL remains fully committed to supporting this agenda through constructive dialogue and practical proposals.

Sincere thanks go to all members who contributed to the consultation and helped shape this response.