The European Fund and Asset Management Association (EFAMA) welcomes the Digital Fitness Check and the European Commission’s initiative to review the EU Digital Rulebook and assess how it can be improved to better support innovation and help position Europe as a global leader in critical technologies.

The European investment management industry plays a crucial role in steering capital toward investments that deliver long-term value for clients, promote economic prosperity, and enable Europe to pursue its strategic interests. Moreover, our firms operate in a highly regulated environment, widely regarded as a safe and robust framework that protects investors and addresses risks to the EU's financial stability.

We consider that much of the EU’s digital regulation, which is horizontal in nature and applies across multiple sectors, overlaps with the detailed, sector-specific rules already applicable to the investment management industry. This creates unnecessary duplication and additional burden, particularly where the risks targeted by digital regulation are already addressed under existing financial regulatory frameworks.

In this paper, we set out key digital legislative files that could be significantly simplified, in particular by removing duplicative obligations for firms in the financial services sector.