Response to Commission Consultation on Fintech

FESE considers that FinTech can be an important driver to expand access to financial services for consumers, investors and companies, bringing greater choice and more user-friendly services, often at lower prices. New financial technologies can help individuals as well as small and medium-sized enterprises, including start-up and scale-up companies, to access alternative funding sources for supporting their cash flow and risk capital needs.

FESE believes it is worth highlighting the importance of establishing key principles upon which Europe can build a role in facilitating the development and implementation of FinTech. These principles include the need for:

• The application of the same rules for the same services and risks based on the principle of technology neutrality;
• A risk-based approach built on proportionality and materiality which allows for flexibility, particularly in respect of innovation with small groups of customers, while ensuring a level playing field across the EU;
• A balancing of the local risks alongside the benefits of cross-border markets.

As FinTech develops, FESE believes the principles of flexibility, materiality and proportionality are, in particular, critical to allow for the emergence of disruptive technologies. At this stage, we consider that there are limited grounds for major changes to EU legislation and certainly no need for the development of a specific EU framework, particularly in a regulatory sense, for FinTech.