The European Banking Federation (EBF), along with other financial services Associations [European Mortgage Federation-European Covered Bond Council (EMF-ECBC), Lease Europe, Eurofinas, European Association of Cooperative Banks (EACB) and European Savings Banks Group (ESBG)] providing financial services, have been closely monitoring the ongoing legislative developments in view of the upcoming review of the Distance Marketing of Financial Services Directive (DMFSD).

We acknowledge the value of enhancing the “safety net” feature of this newly introduced legislative text, as well as those principles underpinning consumer protection, namely the right to withdraw. However, we have identified key points, worthy of attention and due consideration, such as IT rearrangements linked to withdrawal button, the reminder of such online function, with the aim of  granting sufficient room for manœuvre to financial services providers so they can adjust IT solutions suitable for consumers and bespoke to their business model. Furthermore, we seek to emphasize that the proposal on reviewing the DMFSD, as put forward by the European Commission, is meant to review rules mainly governing the financial services sector; thus, we are not in favour of extending the relevant DMFSD provisions to the whole spectrum of the Consumer Rights Directive. Lastly, the prevalence of sectoral specific rules, in the interplay with the general ones set out in the new DMFSD is of utmost importance in order to ensure legal certainty, in the context of EU better regulation principles.