Position Papers

• Corporate Sustainability Due Diligence Directive (CSDDD) ABBL & ACA positions on issues of scope and application
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  Created at: 08-12-2022
• Draft Law on a pilot scheme for market infrastructures based on DLT ABBL comments on Blockchain III bills of law
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  Created at: 20-03-2023
• ABBL response on EU withholding tax system Commission consultation on a new system for withholding taxes on dividends and interest payments: ABBL response
  Reserved for Members
  Created at: 18-07-2022
• Targeted consultation on the digital euro ABBL response to ECB consultation seeking further information from industry experts
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  Created at: 20-03-2023
• Retail investment package ABBL response to the EC call for evidence on the new package of measures
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  Created at: 28-06-2022
• ESMA consultation on MiFID II suitability requirements ABBL position on options to enhance the suitability assessments 
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  Created at: 06-05-2022
• Misuse of shell entities for tax purposes (ATAD 3) ABBL comments on the EU Proposed Directive
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  Created at: 03-05-2022
• EC consultation on suitability and appropriateness assessments ABBL position on a single standardised questionnaire
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  Created at: 28-03-2022
• Capital Requirements Regulation ABBL priorities on the EU Commission Proposal amending the Capital Requirements Regulation 
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  Created at: 10-02-2022
• Direct Provision of Banking Services in the EU by Third Country Undertakings ABBL position on the EU Commission Proposal amending the CRD
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  Created at: 04-05-2022
• New reporting obligation under Belgian law ABBL letter to the National Bank of Belgium
  Reserved for Members
  Created at: 10-02-2022
• Proposal for a Directive on Consumer Credits ABBL comments on the Proposal for a Directive of the European Parliament and of the Council on consumer credits
  Reserved for Members
  Created at: 17-12-2021
• EU AML/CFT package ABBL comments on the EU AML/CFT package
  Reserved for Members
  Created at: 17-12-2021
• ABBL opinion on the ECB consultation on Euro Digital Financial, payment and technology professionals' perspective  
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  Created at: 20-03-2023
• Draft Law amending the law on dematerialised securities Comments on Blockchain II bills of law
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  Created at: 20-03-2023
• Draft Law amending the law on the circulation of securities ABBL comments on Blockchain I bills of law
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  Created at: 20-03-2023