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 most recent package for the simplification of sustainability reporting (including the delegated acts resulting therefrom), the revision of the Sustainable Finance Disclosure Regulation (SFDR) 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), according to an approach aimed at encouraging innovation on the one hand and the protection of consumers and investors on the other.

In this context, the Group operates in compliance with competition law, including with regard to its participation in ESG initiatives in the environmental field, encompassing forms of collaboration among market participants, in line with the principles of an open and competitive market.

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 topics related to the digitalization of the banking sector, 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, by way of example, legislative proposals concerning digital matters and the Framework for Financial Data Access (FiDA). 

On the subject of Artificial Intelligence, the Group continues to monitor developments in the AI regulatory framework (AI Act), responding to public consultations and following the simplification proposals published at the end of 2025, also with a view to its strong commitment to the principles of responsible AI.

Lastly, with regard to the retail payments sector, the PSD2 review package has been subject to monitoring and advocacy activities. 

From the point of view of banking regulation, the Institutional Affairs Directorate (DIA) during 2025, by way of example, 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) to the review of the European securitisation framework.

Regulatory matters relevant to the Group, both at national and EU level, with particular reference to the objectives of the Business Plan, are summarised in the Regulatory Agenda, which is periodically presented to the Board of Directors and the CSR Committee.

Furthermore, in order to relaunch the securitisation market, the Bank has actively contributed to the ongoing debate in the context of the legislative proposals concerning the Securitisation Regulation (SECReg) and the prudential treatment (CRR), which are currently under the EU legislative process.

As regards financial markets, all regulatory initiatives falling within the scope of the new Savings and Investments Union (SIU) Strategy, which builds on the EU’s previous Capital Markets Union (CMU) action plan, are being monitored and are the subject of advocacy activities. 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); (iv) initiatives on Savings and Investment Accounts (SIA) and on financial education; and (v) the Market Integration and Supervision (MISP) package, presented at the end of 2025.

The Group functions involved are constantly updated through periodic newsletters regarding European policies for growth, innovation, business support, digital policies and those regarding banking, financial and insurance 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.