Digital, Innovation, Payments
ABBL calls for meaningful simplification of the EU digital rulebook
Published on 25 March 2026
As the European Commission seeks to streamline the EU digital rulebook, the ABBL calls for meaningful simplification that reduces complexity, enhances legal clarity and delivers real operational benefits for financial institutions.
Summary
The ABBL has submitted its response to the European Commission’s consultation on the Digital Omnibus and the broader effort to simplify the EU digital rulebook.
This consultation forms part of the Commission’s wider competitiveness agenda and its attempt to reduce the cumulative burden created by overlapping digital rules across the EU. According to the Commission, the Digital Package aims to generate up to €5 billion in administrative savings by 2029, while European Business Wallets could unlock additional savings of up to €150 billion per year for businesses.
Read ABBL's position paper
A growing need for coherence across digital regulation
In its response, the ABBL welcomes the Commission’s objective of making the EU framework more coherent, innovation-friendly and easier to implement in practice.
From the perspective of financial institutions, this is a timely initiative. Banks are increasingly required to comply simultaneously with multiple horizontal and sector-specific regulations, including GDPR, NIS2, DORA, the AI Act and the Cyber Resilience Act.
As highlighted in the ABBL’s position paper, the main source of complexity is not simply the number of reporting channels or interfaces. It lies in the fragmentation of legal definitions, notification triggers, assessment obligations and supervisory processes across different frameworks.
The ABBL supports the Commission’s ambition to simplify the EU digital rulebook, but simplification must lead to real operational relief. Our response sets out practical recommendations to make the framework clearer, more coherent and more workable for financial institutions, while preserving resilience, legal certainty and Europe’s capacity to innovate.
Andrey Martovoy
Senior Adviser - Innovation & Digital, ABBL
Towards a single-entry point for reporting
A key element of the ABBL’s response is its support for the proposed Single-Entry Point for incident and breach reporting, provided it delivers genuine structural simplification.
The ABBL stresses that this mechanism should replace existing parallel reporting channels under GDPR, NIS2 and DORA, rather than become an additional layer of reporting.
For the financial sector, DORA must remain the lex specialis, with supervisory responsibilities preserved and duplication avoided.
Simplification must go beyond reporting
The ABBL also calls for broader simplification through greater coherence across the EU digital acquis.
This includes:
- harmonising core concepts and regulatory triggers
- enabling the re-use of assessments across legal frameworks
- ensuring institutions do not face multiple overlapping compliance exercises for the same operational event
Competitiveness in Europe will not be driven by adding layers, but by making the framework intelligible and workable. When institutions have to reconcile diverging requirements across GDPR, DORA and NIS2, complexity becomes a burden in itself. Simplification should remove that friction and allow firms to focus on what truly matters: delivering secure, innovative and compliant services.
Amandine Laurent
Legal Advisor, ABBL
AI: balancing simplification and legal certainty
On artificial intelligence, the ABBL supports the Commission’s simplification efforts but stresses the need for greater legal certainty, particularly regarding the definition of AI systems and the treatment of financial-sector use cases under the AI Act.
In particular, the ABBL:
- calls for traditional deterministic statistical techniques to be clearly excluded from the definition of AI systems
- highlights the need to avoid unnecessary legal uncertainty and over-classification
- advocates for a more predictable timeline for high-risk obligations
- calls for a more proportionate treatment of financial use cases, such as fraud prevention and AML tools
The ABBL welcomes efforts to address implementation challenges of the AI Act but notes that proposed simplifications introduce new uncertainties through conditional timelines, reliance on future guidance, and unresolved questions around roles and regulatory interactions. The ABBL calls for binding clarification of AI system definition, excluding traditional statistical models and avoiding unnecessary regulatory overlap.
Galina Miroshnichenko
Adviser – Payments & Digital, ABBL
An opportunity to improve regulatory quality in Europe
More broadly, the ABBL sees the Commission’s digital simplification agenda as an important opportunity to improve the quality of regulation in Europe.
Simplification should result in a framework that is:
- clearer
- more proportionate
- more workable in practice
while continuing to preserve resilience, data protection and fundamental rights, and supporting innovation and competitiveness.
As the Commission continues its Digital Fitness Check and broader review of the digital acquis, the ABBL will remain actively engaged in ensuring that the voice of the banking sector is heard, and that simplification translates into tangible operational benefits for financial institutions and their customers.
Andrey Martovoy
Senior Adviser - Innovation & Digital, ABBL
Published on 25 March 2026