This position paper outlines the ABBL’s views on key elements of the EU Digital Package, focusing on the proposed Single-Entry Point (SEP) for incident and breach reporting and the amendments to the AI Act under the Digital Omnibus. It highlights the challenges posed by overlapping digital regulations such as GDPR, NIS2, DORA and the Cyber Resilience Act, and calls for a more coherent, streamlined and proportionate regulatory framework. The document supports the introduction of a single reporting channel, provided it replaces existing parallel obligations and is accompanied by harmonised definitions and aligned notification triggers. It also provides detailed recommendations on AI regulation, including the need for greater legal certainty, clearer classification of high-risk use cases, proportional implementation timelines and stronger alignment with existing financial sector frameworks. Overall, the ABBL advocates for structural simplification, improved regulatory coherence and a sector-led supervisory approach to support innovation, resilience and competitiveness in the European financial sector.
