AmCham EU response to the Sustainable Finance Strategy Consultation
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Aligning EU securitisation rules with global markets
The European Parliament’s November 2025 draft report on revitalising EU securitisation strengthens the Commission’s proposal by pushing further simplification, but it overlooks a central flaw in the framework: the misalignment between EU and non‑EU securitisations that continues to restrict EU investors’ access to global markets. Investor access should depend on whether sufficient information is available for due diligence, not on the use of a specific reporting template.
MEPs can make this fix by removing the template‑based verification requirement in Article 5(ii)(e) and anchoring investor due diligence in a clear, substance‑based ‘sufficient information’ standard. When combined with the Parliament’s encouraging simplification proposals, this targeted fix would lower operational costs, enable proportionate due diligence and strengthen market depth – all without weakening core safeguards.
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Revitalising EU securitisation
Mobilising private capital for long-term, productive investments is critical to advancing the EU’s green and digital transitions and realising the objectives of a Savings and Investments Union (SIU). However, the EU securitisation market has seen a significant decline since the global financial cri-sis and has since continued to lag behind comparable markets. Previous efforts to revive the EU secu-ritisation market, such as the introduction of the EU Securitisation Regulation and the Simple, Trans-parent and Standardised (STS) label for traditional securitisations have not meaningfully improved the situation.
Whilst not the panacea to all of Europe’s funding challenges, learn why revitalising securitisation in Europe will help unlock private finance and thereby create better conditions for the financing of the EU economy.
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Omnibus I: the EU shows it can deliver on simplification, but global firms need further certainty
The Omnibus I political agreement announced yesterday broadly eases the sustainability compliance and due diligence burden for businesses under the Corporate Sustainability Due Diligence Directive (CSDDD) and the Corporate Sustainability Reporting Directive (CSRD), giving much-needed certainty to businesses. It is a significant achievement for the EU’s simplification agenda and ongoing efforts to reduce the regulatory burden. Specifically, the flexibility introduced in terms of the risk-based approach and how companies need to define adverse impacts will alleviate most of the excessive burden that existed under the original CSDDD. The revised transposition timeline of CSDDD to 2029 will also give all parties the necessary time to prepare for implementation.
However, it appears that EU policymakers did not yet sufficiently tackle how these rules apply to the global activities of companies and groups – for example, by limiting the scope of the CSDDD to only those products and services with a logical link to the EU. This is a missed opportunity with far-reaching consequences that keeps legal uncertainty in place for global firms and their supply chains. This oversight on extraterritorial impact will make the CSDDD more difficult for policymakers to implement and monitor and risks creating confusing overlap with other jurisdictions’ rules.
The EU must use the next steps in the policy-making process – including implementing measures, guidance and future reviews – to fix outstanding challenges in both the CSDDD and the CSRD. In particular, clearer rules on when and how EU legislation impacts global business activities would give companies the predictability they need to invest and support sustainability investments.
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