EDFA’s Response to the European Commission’s Call for Evidence on Savings and Investment Union
The European Digital Finance Association (EDFA) warmly welcomes the opportunity provided by the European Commission to participate in the Call for Evidence regarding the Savings and Investment Union.
As the leading umbrella organisation for national digital finance (Fintech) associations across EU member states, EDFA represents numerous Fintech enterprises directly impacted by EU policy decisions aimed at deepening the Capital Market Union (CMU). Over recent years, initiatives under the CMU have significantly enhanced digital efficiency within traditional financial services, simultaneously driving substantial growth in the European Fintech sector.
The robust and innovative Fintech ecosystem emerging in Europe plays a critical role in maintaining the competitiveness of the broader European economy. Fintech services have become essential to business operations for start-ups, SMEs, and large corporations alike. To ensure resilience and strategic autonomy, European policymakers should prioritize reducing dependency on non-European Fintech solutions, particularly considering the potential impacts of global trade tensions between the US, Europe, and China.
Europe’s Fintech ecosystem has successfully expanded financial inclusion by providing digital financial services—such as electronic wallets, digital investment products, electronic shares, online loans, and digital insurance—to millions of customers previously underserved by traditional financial institutions. The collaborative synergy between Fintech firms and established financial institutions has notably enhanced the competitiveness and service quality offered by European banks. Therefore, we strongly endorse ongoing efforts that encourage traditional financial institutions to collaborate with Fintech providers, facilitating innovation and broadening consumer access to advanced financial services.
We believe the Savings and Investment Union should actively integrate innovative solutions from the Fintech sector. Current policy approaches in some member states still disproportionately focus on traditional finance models, neglecting the transformative potential of digital finance. EDFA strongly encourages the European Commission to leverage the significant role Fintechs can play in realizing the objectives of the Savings and Investment Union. We particularly commend DG FISMA for pioneering Digital Finance Hubs, a move we fully support and are eager to contribute to actively.
To achieve a successful pan-European scale-up of Fintech services, the Commission must effectively address uneven regulatory implementations across member states—a practice known as “gold-plating.” Such discrepancies create unnecessary friction and hinder the seamless cross-border provision of digital financial services. Ensuring harmonization and regulatory consistency is essential for fostering a thriving, interconnected European Fintech market.
Furthermore, Fintech companies have developed expertise in efficient and customer-centric communication and business processes. Yet regulatory frameworks frequently overlook the inherently digital nature of these services, imposing disproportionate burdens, especially regarding processes like Know Your Customer (KYC). To truly achieve a level playing field within the Savings and Investment Union, regulatory measures should equally apply to both traditional and digital finance, removing unnecessary friction and encouraging innovation.
Another critical opportunity is opening traditional savings accounts for investment in society’s broader digital and green transitions. Today, Europe faces substantial challenges that require extensive investment. However, retail investors often lack easy access to investment opportunities through their existing digital accounts. Fintech solutions are uniquely positioned to bridge this gap, empowering consumers with greater investment choices and actively supporting Europe’s transformative goals.
In conclusion, EDFA is committed to constructively supporting the European Commission’s efforts to create a regulatory environment that fosters innovation, ensures consumer protection, and promotes financial inclusivity, ultimately strengthening Europe’s competitive edge in global digital finance.