On 11 February 2025, the European Commission published its 2025 work programme, accompanied by a Communication on implementation and simplification and relevant Annexes – link here. The Communication outlines the Commission’s strategy to create faster, simpler, and more effective rules, while the programme lays out what the Commission will work on in terms of new initiatives, withdrawn proposals, ongoing proposals making their way through the legislative process, and repeals. While the Communication shows the new ways of working of the Commission, this blogpost focuses on the 2025 work programme for financial services, which provides a good overview of what to expect in the year ahead. However, given the fast-changing political landscape, we might see other initiatives gaining traction or momentum in 2025.
Background
The 2025 work programme is framed against the backdrop of the new Commission´s plans on simplification in order to boost the bloc’s competitiveness (see here our outlook on the von der Leyen II Commission). While some familiar challenges remain, such as support for Ukraine or the energy crisis (see 2023 work programme) there are new mantras that are here to stay: the Commission’s push for effective implementation and enforcement of existing pieces of legislation, but potentially more significantly, simplification of existing laws. The message from the Commission in the new mandate is clear: reducing reporting obligations by at least 25%, and by at least 35% for small- and medium-sized enterprises (SMEs).
This vision was reinforced by the publication of the Competitiveness Compass on 29 January 2025 and the announcement of the publication of a first Omnibus to simplify the sustainable finance architecture (Taxonomy, CSRD and CSDDD), expected by the end of February or early March 2025, and followed by additional omnibus simplification packages in the course of the year
While the Omnibus announcement was radical and took all of industry by surprise, what we see now is a clear will from the Commission to push this simplification agenda much further, which is rapidly gaining momentum and moving far beyond sustainability or corporate reporting and into other sectors such as financial services and digital. This is further confirmed by the Commission’s 2025 work programme outlined here in more detail. Commissioner Dombrovskis, who spoke about the work programme at its unveiling to the press, underlined that the EU is “emerging from a period of intense regulatory activity” and as such, “the accumulation of rules over time limits the EU’s economic potential and prosperity”. When challenged on this new approach that the Commission is pursuing, Commissioner Dombrovskis recalled that the idea of reviewing legislative frameworks is not new nor unprecedented, and that a similar exercise was carried out after the global economic crisis when a large numbers of new legislation were put into place and the Commission later undertook a call for evidence and streamlined its rulebook. While one could argue that a similar approach is being pursued by the Commission now, the level of ambition is far higher and the results far more unpredictable.
Last minute revival of the open finance proposal
On 03 July 2023, the Commission published the proposal on a framework for Financial Data Access or so-called FIDA (see here our blogpost). The Commission published this proposal, demonstrating its commitment to bringing the wider financial sector into the digital age by securing and opening access to customer data across a broader range of financial services. Following the approval of the ECON Committee position, the Parliament decided to enter into interinstitutional negotiations in December 2024. On 04 December 2024, the Council adopted their FIDA General Approach to enter trilogues. While trilogues were set to begin in March 2025, leaked versions of the Commission’s 2025 work programme took an unexpected approach by including FIDA in the list of proposals to be withdrawn – a fate usually reserved for initiatives that have been stuck in negotiations for months on end, often years, and that stand little to no chance of ever being approved.
Finally, however, the official 2025 Commission work programme listed FIDA under the heading of pending proposals, meaning negotiations will continue, preventing the file from being abandoned. Why is this seemingly small change significant? The last minute changes affecting the status of FIDA shows that this new Commission is ready to scrap initiatives it thinks are too burdensome on industry even when negotiations are in full force, and that despite the decision to have FIDA removed by the very highest ranks in the Commission, individual services such as DG FISMA and the new financial services Commissioner were able to push back. In the specific case of FIDA, it should be noted that if political disagreements persist or discussions stall, withdrawal could still be an option. A withdrawal would likely spark mixed reactions from industry stakeholders and consumer protection groups. Meanwhile, with the US and UK leading in Open Banking and Open Finance, the EU’s next steps in financial data sharing—and its potential for monetization—will be crucial to watch. (See our 2025 Fintech Predictions for more insights).
Revamping the Savings and Investments Union
The Commission's work programme includes a forthcoming Communication on the Savings and Investments Union, planned for Q2 of 2025. This non-legislative initiative will be shaped by feedback from the call for evidence that opened on 03 February 2025 and will be closed on 03 March 2025 (see link to the call for evidence).
As suggested in the Letta and Draghi reports (see here our takeaways from the Letta and Draghi reports), the Capital Markets Union has been rebranded as the Savings and Investments Union, but its core objective remains the same: unlocking funding to drive Europe’s growth and competitiveness. The Savings and Investments Union aims to help households grow their wealth by improving returns on savings while also expanding financing opportunities for businesses. The Commission aims to address a key issue: EU capital markets lack sufficient opportunities, scale and depth, with cross-border business still facing many barriers. To fix this, the Commission is gathering feedback specifically on the progress made so far and the remaining challenges for making progress on the Savings and Investments Union.
Other key new initiatives
When it comes to other novelties and following the line of focusing on investment, simplification and cutting red tape, the Commission is also planning a third Omnibus package on investment simplification as well as a review of the existing Securitisation Framework, both slated to come in Q2 of 2025. What is clear is that the Omnibus on sustainable finance will set a precedent on the Commission’s approach to legislation and will lead the way for the other Omnibus initiatives that will follow.
Regarding other key topics, the Commission launched on 18 June 2024 a targeted consultation on artificial intelligence in the financial sector and it is currently analysing the feedback received. With the targeted consultation having closed on 13 September 2024, the Commission is likely to follow up with a non-legislative initiative in the future. While this workstream has not been included in the work programme, this might come in 2026. For now, in parallel to the work of the Commission to ensure the proper implementation of the AI Act (see here our AI Insights), the Parliament has kicked off work on an own-initiative report on AI in financial services. While the timeline for this non-binding report is still under discussion, it is likely to feed into future discussions and influence the Commission’s work.
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