Relations with national, European and international institutions and advocacy actions

The political centrality of environmental sustainability (in all its forms) is also demonstrated by the intensity of legislative activities linked to this priority, among which we can mention the work attributable to the “renewed strategy for sustainable finance” and the most recent package for the simplification of sustainability reporting and the presentation at the beginning of 2025 of the new “Clean Industrial Deal” strategy which builds on what had already been foreseen in previous years through the “Fit for 55” and “RepowerEU” packages. In particular, all activities directly linked to the EU sustainable finance framework are directly relevant for Intesa Sanpaolo.

The advocacy and monitoring activity of the European Commission's legislative initiatives on sustainable finance also continued and the Group continued to participate in the working tables on Sustainable Finance of the European Banking Federation (FBE), of the European Mortgage Federation (EMF-ECBC) and the Association for Financial Markets in Europe (AFME). Furthermore, Intesa Sanpaolo continued to promote its distinctive positioning in terms of financing the circular economy towards relevant stakeholders.

In the field of banking digitalisation, there is constant coordination of internal and the participation to that organised by the associations, such as innovative digital payments, cybersecurity, artificial intelligence, data economy and open finance, digital euro, digital identity, new digital assets (such as crypto-asset ), with the aim of promoting a regulatory framework in line with the Group's position at European level, according to an approach aimed at encouraging innovation on the one hand and the protection of consumers and investors on the other.

Intesa Sanpaolo participates in the tables promoted by the EMF-ECBC in the Energy Efficient Mortgage Initiative, in order to consolidate best market practices and dialogue with EU institutions. This initiative, in addition to our EU peers, also involves the ABI and Italian banks.

Collaboration with European trade associations continued on these issues, which saw the participation of Intesa Sanpaolo experts in the thematic working groups that defined the industry's positions on the main European initiatives in the digital field.

The Group is monitoring the second level legislation of the regulation on the DORA-Digital Operational Resilience Act, which is part of the broader "Digital Finance" package and which aims to make the financial sector more resilient to cyber risks and the policies and strategies of the new European Commission on the security issues.

Regarding the establishment of a European digital identity framework, the Group participates in the activities of the European Union pilot project for testing the European Digital Identity Wallet (EDIW) for payment purposes.

On the subject of Artificial Intelligence, the Group has followed the legislative process on the AIA-Artificial Intelligence Act, now adopted, also with a view to its strong commitment to the principles of responsible AI. monitoring the evolution of the regulamentation.

Finally, the proposal for a European regulation on data sharing (so-called FIDA) is also the subject of attention, which aims to open the financial data of European customers to third parties - on the basis of their prior consent - and which presents critical aspects also relating to security and fraud.

From the point of view of banking regulation, the Institutional Affairs Directorate (DIA) during 2024 followed the legislative process relating to i) the implementation of the new legislation on capital requirements, ii) the management of banking crises and the completion of the Banking Union, iii) initiatives regarding financial services and capital markets and iv) legislative proposals regarding retail credit.

Furthermore, to relaunch the securitisation market, the Bank has participated in the initiatives promoted by the EU institutions in the context of the Capital Markets Union and recently of the Savings and Investment Union, also contributing to the possible definition of green securitisation.

As regards the financial markets, the regulatory initiatives falling within the scope of the new EU action plan on the Capital Markets Union (CMU) are monitored and object of advocacy. As regards the CMU, the ESAP (European Single Access Point Regulation) legislative initiative was carefully followed. The initiative aims to promote the establishment of a platform that acts as a single and centralized point at EU level for free access to relevant information (including ESG information) on EU companies, financial and non-financial, listed and unlisted (including SMEs) subject to potential investment, in order to give them greater visibility towards investors.

The following European legislative initiatives were also the subject of attention: i) Listing Act, aimed at promoting access to the capital market for SMEs; ii) EMIR 3.0, which revisits the regulatory framework of derivatives clearing houses, also essential from a post-Brexit perspective; iii) the revision of the regulation on central depositories (CSDR).

Lastly, as regards the retail payments sector, the Directive and regulation on payment services (PSD3 and PSR) and the legislative package relating to the digital euro are being monitored.

The Group functions involved are constantly updated through periodic newsletters regarding European policies for growth, innovation, business support, digital policies and those regarding banking and financial market regulations. Targeted updates are also sent (so-called EU Regulatory Alerts), if significant regulatory changes occur that require the attention of the internal functions concerned. In particular, specific impact analyses are activated on certain regulatory proposals to assess the repercussions on the Group's strategy and activities. Depending on the priority indicated by the internal functions, a Group position is defined to be represented to the European institutions and other stakeholders. In order to make the activity of the internal working groups more effective, support and training is provided to the Group's operational and business structures, in particular through seminars aimed at presenting the peculiarities of the European legislative process, updating them on the legislators' orientations during the legislative process, illustrating the status and details of the relevant current and future regulatory dossiers.

Since the SSM (Single Supervisory Mechanism) was launched at the end of 2014, the Department maintains an ongoing relationship with the Single European Supervisor, coordinating the Group's annual supervision plan, aiming to ensure due consistency and uniformity in interaction processes with the supervisor and to promote a widespread culture of "supervisory awareness" to increasingly strengthen the capacity to respond to Supervisor's requests. The Bank also maintains, through its dedicated structures, an ongoing relationship also with the Single Resolution Board, the EU authority responsible for managing the resolution of large banks in difficulty.