ALFI responds to the European Commission targeted consultation on integration of EU Capital Markets

Driven by the vision of a more competitive Europe, ALFI has expressed its support for the Savings and Investments Union (SIU) initiative, a strategic effort to transform passive savings into active investment for individuals, businesses, and the broader economy. A key focus should also be on strengthening pension systems with funded pension models and securing long-term financial sustainability for European citizens. ALFI has recommended a set of concrete actions in relation to the SIU initiative in the ALFI Blueprint for Savings & Investments, dated March 2025.

In general, ALFI considers that the current AIFMD and UCITS frameworks are functioning well and has cautioned against further revisions to the UCITS and AIFM Directives, especially so soon after the most recent amendments, which are still in the process of being implemented.  It firmly opposed altering frameworks that are already functioning effectively, emphasizing the principle that “what works well should not be fixed.”

ALFI stressed the importance of avoiding overlapping regulatory obligations, advocating instead for a focus on enhancing efficiency and cost-effectiveness for both the industry and supervisory authorities. It also emphasized the urgent need to simplify investor disclosures and to streamline reporting requirements, ensuring that only data essential for supervisory purposes is collected. In addition, ALFI expressed its support for a revision of the DLT Pilot Regime, aimed at encouraging broader market participation and strengthening secondary market trading through more resilient and scalable DLT-based platforms.

ALFI has consistently emphasized the need to eliminate cross-border barriers within the EU, noting that the main cross-border obstacles arise from national legal frameworks, which cannot be effectively resolved through centralised supervision. Accordingly, ALFI has repeatedly advocated for greater convergence of regulations and practices between Member States, as well as enhanced cooperation among national competent authorities. In this context, ALFI supports ESMA’s continued coordinating role under its current mandate. However, ALFI firmly opposes any transfer of supervisory powers to a single EU-level authority, as such a move would introduce unnecessary complexity and costs for market participants, offer no tangible benefit to the industry, and is unlikely to be operationalised within a reasonable timeframe.

Finally, ALFI welcomed the Commission’s initiative to establish a dedicated reporting channel, enabling all market participants including individuals and businesses to flag obstacles to financial market integration within the EU Single Market.

Read the full response here.