EU Commission publishes its 2025 Recommendation and blueprint for Savings and Investment Accounts

RegCORE Client Alert | Capital Markets Union + Savings and Investment Union

QuickTake 

On 30 September 2025, the European Commission published an EU Recommendation aimed at increasing the availability and uptake of EU-wide Savings and Investment Accounts with simplified and advantageous tax treatment (EU-SIAs) across EU Member States. The Recommendation sets out a European blueprint for EU-SIAs, with the objective of boosting retail investor participation in capital markets, supporting long-term wealth creation and advancing EU strategic priorities such as the digital, green and social transitions.

Arguments for creating EU-wide and portable investment products to foster retail investor market participation have been raised multiple times before. This is the case in particular given various EU Member States having successful national EU-SIA regimes and the EU’s efforts to establish a Capital Markets Union (CMU), which was first launched in 2015 and amended and supplemented in the decade that following, having advanced a pan-European personal pension product (PEPP) along with various fund products and pan-EU wide regimes. The EU-SIA however aims to go a step further than what CMU achieved.

The EU-SIAs are a central component that carried through from the CMU into the March 2025 rebrand to establish a broader Savings and Investments Union (SIU). EU-SIAs complement a number of existing EU regulatory and supervisory frameworks, including those that are CMU/SIU specific, such as the Retail Investment Strategy (RIS)See standalone coverage on all SIU and RIS themes available from our SIU website and thought leadership on our EU RegCORE website.Show Footnote and should also be read in conjunction with the European Commission’s new EU-wide Financial Literacy Strategy (EU-FLS), which it announced in parallel on 30 September 2025.Relevant documents and links to the press conference available here. Please also see a standalone Client Alert on the EU-FLS available from our EU RegCORE website.Show Footnote

This Client Alert summarises the key features of the EU-SIA blueprint set out in the Recommendation, the policy rationale along with the legal, regulatory and supervisory expectations for Member States and market participants. While the Recommendation is non-binding, it is expected to shape national frameworks plus supervisory expectations of the European Supervisory Authorities (ESAs)Comprised of the (i) European Banking Authority (EBA), (ii) European Securities and Markets Authority (ESMA) and (iii) European Insurance and Occupational Pensions Authority (EIOPA).Show Footnote along with those of national competent authorities (NCAs) and thus market practice. This Client Alert should be read in conjunction with a number of other Client Alerts on SIU and equally on CMU topics that have already been delivered or which remain subject to delivery as part of the SIU.

A blueprint is a good start but it is also conceivable (perhaps even welcome and much needed) that the EU’s current plans on EU-SIAs might evolve more fundamentally given that the blueprint, as discussed below, may not at present go as far as it could or indeed many market commentators think it perhaps should.Please also refer to inter alia to the 2021 article of M.Huertas & T.Voss in “CMU 2.0 – the continued need for greater retail investor participation and continued arguments for an EU-wide ISA” as well as an updated article assessing how the EU-SIA blueprint may not go as far as the proposals suggested in the aforementioned 2021 article.Show Footnote A key issue is that under the Recommendation, retail investors and providers will still face a patchwork of (national) SIA variants.

Rationale and key objectives of EU-SIAs

The Commission identifies several barriers to effective retail participation in capital markets, including insufficient financial literacy, complex investor journeys, fragmented markets and limited competition. Despite high savings rates among EU citizens, these factors often prevent individuals from achieving optimal returns on their savings. A number of these issues predate the SIU let alone the CMU. 

To address these issues, the blueprint seeks to facilitate retail access to capital markets through simplified, user-friendly and often tax-advantaged EU-SIAs; to encourage competition and innovation among providers; to promote cross-border investment and reduce fragmentation; to support financing of EU strategic priorities by broadening the retail investor base; and to enhance financial literacy and awareness of opportunities and risks. In policy terms, the initiative is a core pillar of the SIUFor further information on the SIU, please refer to: https://www.pwc.de/de/finanzdienstleistungen/chancen-durch-savings-and-investments-union.html.Show Footnote and builds on Eurogroup and European Council commitments to deepen retail participation in capital markets. 

The Recommendation and its blueprint aims to:

1. Facilitate retail access to capital markets through simplified, user-friendly and tax-advantaged EU-SIAs.
2. Encourage competition and innovation among financial service providers.
3. Promote cross-border investment and reduce market fragmentation.
4. Support the financing of EU strategic priorities by broadening the retail investor base.
5. Enhance financial literacy and awareness of investment opportunities and risks.

From a legal standpoint, the instrument is a Recommendation under Article 292 of the Treaty on the Functioning of the European Union (TFEU) addressed to Member States. It does not impose direct obligations on firms, but it sets out clear expectations that Member States should establish or adapt national EU-SIA frameworks in line with the blueprint, enable cross-border provision by any EU-authorised provider without host-state add-ons and simplify tax compliance, including allowing foreign providers to use domestic tax processes. 

The Commission will monitor implementation through the European Semester and the SIU Midterm Review in 2027, creating policy momentum for near-term actions at a national level. For firms, this means tangible changes: supervisory guidance, operational standards for transfers and tax collection or reporting requirements will follow as Member States transpose the blueprint into national practice, often accompanied by retail-focused incentives and awareness initiatives that shift investor flows.

Key features of the EU-SIA blueprint

The core features of the EU-SIA framework cohere around accessibility, provider neutrality, portability, risk-appropriate investment scope, simplicity in user experience and facilitated tax compliance. EU-SIAs should be open to all citizens, including young savers, with no minimum investment requirements and the ability to open multiple accounts across providers. Any financial services provider authorised under EU law to perform relevant services – execution, safekeeping and administration, advice or portfolio management – should be permitted to offer EU-SIAs to residents of a Member State irrespective of the provider’s home authorisation and without additional host-state requirements beyond EU law. The Commission expressly links this to the freedom to provide services and establishment, firmly opposing gold-plating or protectionist barriers in host states.

Portability is central. Member States are encouraged to ensure that EU-SIAs and their assets can be transferred easily between providers domestically and across borders at limited, proportionate administrative cost, with processes streamlined and standardised. Crucially, transfers – whether in-specie or via sell-and-repurchase mechanics – should not trigger taxable events for income tax or jeopardise existing tax benefits, preserving the continuity of tax attributes. Member States are also urged to cooperate to avoid double taxation when investors change tax residence within the EU. For firms, these expectations translate into operational obligations to accept inbound and process outbound transfers efficiently, maintain tax-lot integrity and cost-basis metadata and adapt client terms to reflect capped transfer fees and clear timelines.

On investment scope, EU-SIAs must at a minimum provide access to shares, bonds and undertakings for collective investment in transferable securities (UCITS) (including exchange-traded funds, ETFs). Member States may extend eligibility to other instruments, notably European long-term investment funds (ELTIFs) and, where allowed, retail alternative investment funds (AIFs), thereby enabling exposure to long-term and private markets. Conversely, highly risky or complex financial instruments, including some derivatives and most crypto-assets, are excluded, save where tokenised instruments qualify as financial instruments under EU law. 

Providers are encouraged to offer a broad array of investment options to support diversification across asset classes, geographies, issuers and managers and to make available options that channel investment into EU strategic priorities, including digital, green, social transitions and strengthening EU security and defence. Firms should therefore calibrate retail product offerings toward non-complex, diversified instruments and ensure product governance, suitability and appropriateness frameworks remain fully aligned with the Markets in Financial Instruments Directive (MiFID II), alongside packaged retail and insurance-based investment products (PRIIPs) and UCITS disclosure regimes.

Simplicity, transparency and user experience are recurring themes. EU-SIAs should be simple, reliable, secure and available through user-friendly digital interfaces, complemented by offline channels for inclusivity. Costs and fees must be fair, proportionate, transparent and easy to compare, a direction that dovetails with recent retail investor protection initiatives. The Commission expects streamlined onboarding and administrative processes, clear communications in plain language and high-quality customer support. For firms, this implies revisiting fee structures, inducement policies and bundled pricing, enhancing disclosure clarity and bolstering digital journeys while maintaining accessible non-digital pathways.

Tax operations are a critical implementation pillar. Member States should provide clear, accessible information on tax treatment and put in place simple and, as far as possible, automated tax compliance procedures. Providers may be required either to collect and settle relevant EU-SIA-related taxes on behalf of customers or to share comprehensive data with tax authorities to enable pre-filled tax returns. Importantly, foreign providers should be allowed to follow the same tax compliance procedures as domestic providers, facilitating cross-border competition and portability. The Recommendation further encourages Member States to grant EU-SIAs at least the most favourable tax treatment available to any comparable asset class, product or account, potentially through deductions, exemptions, deferrals or uniform rates. Non-tax incentives, such as lump-sum payments into EU-SIAs, may also be considered. These measures must remain consistent with the free movement of capital and broader EU law, avoid discrimination and be designed to resist avoidance or evasion. 

Monitoring, reporting and best-practice exchange are built into the blueprint. Member States are encouraged to track uptake, assets invested and the impact and budgetary cost of incentives, to evaluate effectiveness and to report regularly through SIU-related monitoring and the 2027 Midterm Review. Best-practice sharing is encouraged to promote alignment and facilitate portability, including measures to avoid double taxation. Awareness-raising and financial literacy campaigns are expected to accompany rollout, targeting all age groups and emphasising both long-term opportunities and risk clarity.

Given these aims, the Recommendation outlines a set of best practices and minimum standards for national EU-SIA frameworks, drawing on successful models within and outside the EU. Key features include:

1. Accessibility and inclusivity

• No minimum investment requirements for opening or operating an EU-SIA.
• EU-SIAs should be available to all citizens, regardless of wealth or age, with specific encouragement for uptake among young people.
• Multiple EU-SIAs may be opened by a single investor, including with different providers.

2. Provider participation and competition

• All authorised financial service providers under EU law should be permitted to offer EU-SIAs, irrespective of their Member State of authorisation.
• Providers from other Member States must not face additional requirements or barriers.
• Strong competition among providers is encouraged to ensure advantageous offers and high-quality service.

3. Portability and cross-border functionality

• EU-SIAs and their assets should be easily transferable between providers, domestically and cross-border, with minimal administrative fees.
• Transfers should not trigger taxable events or jeopardise existing tax benefits.
• Member States are encouraged to cooperate to avoid double taxation when investors change tax residence within the EU.

4. Investment scope and risk mitigation

• EU-SIAs must provide access, at a minimum, to shares, bonds and units or shares in UCITS (including ETFs).
• Broader access to other eligible instruments (e.g., ELTIFs, retail AIFs) is encouraged, subject to national discretion.
• Highly risky or complex financial instruments, including certain derivatives and most crypto-assets, are excluded.
• Providers should offer a wide array of investment options, enabling diversification across asset classes, geographies and issuers and facilitating investment in EU strategic priorities.

5. Simplicity, transparency and user experience

• EU-SIAs must be simple, reliable, secure and accessible both online and offline.
• Costs and fees must be fair, proportionate, transparent and easy to compare.
• Administrative and procedural aspects should be streamlined, with user-friendly digital interfaces and high-quality customer service.

6. Facilitated tax compliance and incentives

• Member States should provide clear, accessible information on the tax treatment of EU-SIAs.
• Tax compliance should be simplified, with providers collecting tax or sharing data with tax authorities to enable pre-filled tax returns.
• Providers from other Member States should be able to follow the same tax compliance procedures as domestic providers.
• EU-SIAs should benefit from the most favourable tax treatment available for any asset class or investment product, with possible incentives including tax deductions, exemptions, deferrals or uniform rates.
• Non-tax incentives, such as lump-sum payments into EU-SIAs, may also be considered.

7. Monitoring, reporting and best practice exchange

• Member States are encouraged to monitor EU-SIA uptake, assets invested and the impact of tax incentives and to report regularly to the Commission.
• Best practices should be shared to promote alignment and facilitate portability across the EU.
• The Commission will monitor implementation through the European Semester and the SIU Midterm Review (2027).

8. Awareness and financial literacy

• Member States should conduct awareness-raising campaigns on the benefits and risks of EU-SIAs, integrated with broader financial literacy initiatives.
• Campaigns should target all age groups, with a focus on encouraging early and sustained saving and investment.

Key implications for Member States and market participants

EU-SIAs, if implemented broadly and consistently with EU law, can catalyse a new, retail centric distribution channel that is portable across borders and tax advantaged at national level. This will favour firms that combine scaled, low cost manufacturing and efficient digital distribution and those able to integrate tax, reporting and portability features into seamless client journeys. Opportunities differ by firm type: EU authorised manufacturers and distributors stand to gain immediate passportable access; specialist infrastructure, data and identity providers can monetise enabling rails; and non EU firms will generally need EU authorised entities or partnerships to participate in retail distribution. Margin compression from fee transparency and inducement constraints will reward efficient operators and white label platforms.

Moreover, cross-border access will be reinforced, with host states expected to refrain from imposing requirements beyond EU law on EU-SIA offerings, enabling broader passported distribution. This means ESAs and NCAs are required to ensure:

• All firms authorised under EU law for relevant services (e.g., investment firms, credit institutions, UCITS/alternative investment fund managers (AIFMs) with top up permissions) may offer SIAs on a passported basis without extra local licensing or “gold plating” tied to the SIA label.
• Avoid local SIA conditions that function as de facto market entry barriers (e.g., local presence, special approvals, product lists restricted to domestic issuers only).
• Clarify the host/home supervisor split for SIA specific obligations: where obligations are “conduct” (host) vs firm wide organisation (home), to avoid supervisory overlap. 

Providers should be prepared to build robust transfer mechanics capable of in-specie movements and cost-basis portability, capping transfer fees to administrative costs and reflecting these obligations in client documentation. Product offerings should prioritise non-complex instruments, with suitable model portfolios and controls to preclude ineligible assets. Tax operations will demand scalable solutions for collecting tax at source and/or transmitting standardised, secure datasets to tax authorities, including onboarding into multiple Member States’ processes on non-discriminatory terms. Enhanced data governance under the General Data Protection Regulation (GDPR) and operational resilience under the Data Operational Resilience Act (DORA) will be pivotal where firms rely on third-party infrastructure, custodians, central securities depositories (CSDs) or RegTechs for transfers and tax reporting. Marketing and customer communications should align with national awareness campaigns while meeting applicable conduct and advertising standards and providing clear explanations of tax features, limitations and potential clawback risks.

Financial services firms should engage with NCAs as frameworks are designed, adapt product and operational offerings to the recommended standards and contribute to awareness and financial literacy efforts to underpin successful rollout. Early movers that invest in cross-border EU-SIA capability, portable tax and transfer infrastructure and retail-appropriate product governance will be best placed to capture growing retail flows while meeting heightened expectations on conduct, transparency and resilience. The potential opportunities can however be summarised as follows:

EU investment firms and retail brokers

EU authorised investment firms are natural SIA distributors. They can bundle SIA wrappers with core brokerage, advisory and discretionary services on a passported basis, growing retail assets and order flow. National tax incentives and portability should lift account opening and contribution volumes, particularly for low ticket savers if minimums are near zero. Firms that already support in specie transfers, tax lot tracking and standardised client reporting can convert switching frictions into acquisition wins. However, MiFID II alignment on product governance, costs and inducements will continue to favour transparent, low fee pricing; scale and automation will be decisive for profitability.

Credit institutions and retail banks

Banks can leverage existing retail franchises, payroll connections and payments rails to capture “default” SIA inflows through salary deferrals, round ups and standing orders. Integrated cash management, custody and investment distribution can support one stop propositions, while pre filled tax reporting and source of funds controls align with established compliance functions. Cross selling potential into mortgages and deposits is material, subject to inducement and tying rules. Banks operating in multiple Member States can exploit passporting and shared platforms to scale a single SIA operating model with local tax overlays.

UCITS managers, AIFMs and ETF sponsors

Manufacturers may gain a privileged advantage. If eligible assets include UCITS (including ETFs) and, optionally, ELTIFs or retail AIFs, managers can position core building blocks for SIA model portfolios. Demand should skew toward broad, low cost, diversified funds that meet suitability/appropriateness thresholds and support PRIIPs key information document (KID) comparability. ETF sponsors, in particular, benefit from transparent, low fee exposure and portability friendly in specie mechanics. Product teams may design SIA optimised share classes, currency hedges and distribution policies (e.g., accumulating share classes to simplify tax). Managers with pan EU distribution will monetise the common blueprint fastest.

Robo advisers and digital wealth platforms

Automated, goal based propositions align naturally with SIA objectives. Robo advisers can translate tax rules and contribution caps into nudges, glidepaths and rebalancing policies while maintaining MiFID II suitability standards. Their cost base is typically compatible with fee caps and transparency demands. Cross border scalability hinges on multilanguage disclosures, PRIIPs KID orchestration and host conduct oversight, all of which are core competencies for digital platforms. Partnerships with banks and employers can unlock payroll linked onboarding at scale.

Life insurers and unit linked providers

Where national frameworks permit, insurers can wrap eligible assets in unit linked contracts that interface with SIA tax incentives. The value proposition includes beneficiary designations, protection riders and long term savings features. However, to remain competitive against UCITS/ETF based offers, charges must be sharpened and disclosure simplified to meet PRIIPs and MiFID style comparability. Insurers with bancassurance networks can distribute at scale; those with cross border freedom to provide services may leverage existing passports subject to host conduct requirements.

Pension funds and occupational scheme providers

Although SIAs are distinct from pensions, providers can position them as complementary voluntary savings accounts for portability gaps, self employed savers and flexible objectives outside pension regimes. Master trusts and institutions for occupational retirement provision (IORPs) with retail facing arms can extend investment menus and advice lite services into SIAs, using shared administration, custody and member communications. Employer partnerships and payroll integration are natural channels, subject to inducement and tying constraints.

Custodians, transfer agents and market infrastructures

Portability and in specie transfers create revenue for post trade operators. Global and sub custodians can monetise cross border asset servicing, tax relief at source/quick refund and corporate actions continuity. Transfer agents with tax lot carry over capabilities will be essential to minimise switching friction. CSDs and central counter parties (CCPs) may benefit indirectly from higher retail participation and settlement volumes, while agent banks can offer cross market nominee and segregated account solutions tailored to divergent property law traditions.

Data, RegTech and TaxTech providers

Tax pre fill, Directive on Administrative Cooperation/Common Reporting Standard (DAC/CRS) alignment, eIDAS identity and DORA grade operational tooling create sizeable addressable markets for specialist vendors. Providers of KID/KIID production, language localisation, cost/charges analytics and target market mapping can embed SIA specific modules into existing compliance suites. Application programming interface (API) based tax engines that support multiple national SIA regimes, portfolio transfer timestamps, cost basis continuity and clawback logic will be in high demand, especially by passported firms striving for a single pan EU stack.

Cloud, outsourcing and ICT resilience vendors

DORA aligned platforms that deliver incident reporting, resilience testing and critical third party oversight frameworks will be directly monetisable. Given the digital features expected for SIAs – transfer portals, onboarding workflows, tax and identity APIs – cloud and software-as-a-service (SaaS) providers can position sector specific solutions. Vendors that support multilingual disclosures, audit trails and granular client data segregation will help providers satisfy GDPR, host conduct supervision and cross border oversight.

Payments institutions and e money issuers

Where allowed, payments firms can intermediate low friction contributions, rounding features and employer payroll flows into SIAs, exploiting SEPA instant rails and payment initiation service/account information service (PIS/AIS) capabilities. Partnerships with investment firms allow payments players to anchor in the customer journey, monetising origination and data while relying on licensed manufacturers for portfolio management.

Crypto asset service providers (CASPs) under MiCAR

If Member States include certain tokenised instruments or distributed-ledger-technology (DLT) based assets within SIA eligibility and subject them to MiFID/Markets in Crypto Assets Regulation (MiCAR) equivalence where relevant, compliant CASPs and DLT market infrastructures could gain a regulated retail channel. The near term opportunity is more plausibly in tokenised UCITS/ELTIF share classes and DLT based post trade efficiencies than in high volatility, complex crypto instruments, which are likely to be excluded by SIA eligibility criteria.

Non EU firms: pathways and partnerships

Non EU firms will generally require an EU authorised entity to access SIA distribution to retail clients. The principal routes are establishing or acquiring EU investment firms, AIFMs/UCITS Management Companies (ManCos) or credit institutions; partnering via white label arrangements with EU authorised distributors; or manufacturing eligible funds under UCITS/AIFMD with EU management companies and distributing through passported channels. Reverse solicitation is not a viable strategy for scaled retail distribution. For global ETF sponsors and asset managers, aligning product ranges with SIA eligible criteria and leveraging EU domiciles (e.g., Ireland, Luxembourg) offer the clearest path to participation. Non EU RegTech, TaxTech and cloud vendors can access demand through EU subsidiaries that meet DORA/GDPR requirements or through partnerships with EU authorised providers as critical third parties.

The ESAs and NCAs are likely to monitor the development and uptake of EU-SIAs, the effectiveness of tax incentives and the alignment of national frameworks with the European blueprint. Member States are expected to report on implementation and uptake as part of SIU monitoring, with a 2027 midterm review to assess progress and inform further policy. Ongoing evaluation and reporting will inform future policy adjustments and the potential for further harmonisation, especially in light of a number of potential challenges. 

Potential EU-wide implementation challenges

While the future may be promising, especially if political will drives rapid harmonisation of the blueprint, several residual implementation challenges remain.

Nature of the instrument

The Commission’s EU-SIA initiative is structured as a non-binding Recommendation under Article 292 TFEU. This means Member States are responsible for designing and implementing national SIA frameworks that operate within EU law parameters, rather than relying on a harmonising Regulation or Directive. These frameworks must align with the Treaties (including free movement of capital, freedom to provide services and establishment and non-discrimination), as well as with the EU financial services acquis such as MiFID II/MiFIR, UCITS/AIFMD/ELTIF, PRIIPs, MiCAR where relevant, DORA, GDPR, AML/CFT and eIDAS.

National SIA rules cannot create additional barriers for cross-border provision by EU authorised firms, nor discriminate against providers or products from other Member States. A practical implication is that the core of SIA rules will be rooted in national tax and civil law, while distribution, conduct, prudential, data and operational resilience considerations remain governed at the EU level. The central legal design challenge is to ensure coherence across these layers.

Eligible assets, product governance and investor protection

Designing the eligible investment universe and distribution framework must dovetail with existing retail investor protections. Member States should define a sufficiently broad and non discriminatory eligible asset set – at a minimum shares, bonds and UCITS including ETFs – and may optionally include ELTIFs and retail AIFs where permitted, while excluding high risk or complex instruments inconsistent with SIA objectives. Rules should align with MiFID II regarding suitability and appropriateness, product governance (including target market and distribution strategy), inducements and transparent disclosure of costs and charges. Availability and translation of PRIIPs KIDs must be ensured where required for retail distribution, leveraging cost and return comparability across SIA options.Implementation of the Retail Investment Strategy, see the standalone reporting on all SIU and RIS topics available on our SIU website and Thought Leadership on our EU RegCORE website.Show Footnote Any incentive to allocate toward 'EU economy' assets must be carefully calibrated to avoid discrimination against non domestic EU issuers or products that could infringe the free movement of capital.

Tax architecture: incentives, compliance, neutrality and State aid

Tax policy is the heart of national SIA implementation and the most complex design dimension. Member States must select the tax treatment model – exemption, deferral, deduction, uniform rate or a hybrid approach – along with annual contribution caps, the treatment of income and asset classes and withdrawal conditions. Provider facilitated tax collection and prefilled reporting should be available, including for passported providers, to ensure simplicity and parity between domestic and cross border offers. Tax rules should allow for portfolio transfers between SIA providers, both domestic and cross border, without triggering taxable events or forfeiting accrued benefits and should accommodate both in-specie transfers and sale/repurchase mechanics. Targeted and proportionate anti abuse and clawback provisions are essential to address early withdrawals, circular transactions and self dealing. State aid risks under Articles 107–108 TFEU must be assessed, with incentives structured as general measures, neutral across asset classes within the eligible scope and accessible regardless of provider location to mitigate selectivity concerns. Cross border residence changes should be addressed to avoid double taxation or loss of benefits on intra EU relocation, coordinated with treaty relief and exit taxation policies consistent with free movement. Integration with DAC/CRS reporting is necessary to align automated reporting and confidentiality.

AML/CFT, onboarding and identity

SIAs should be readily accessible while maintaining strong compliance standards. Remote onboarding using electronic identification and trust services must be enabled consistent with eIDAS/eIDAS2 and national AML frameworks, with parity for foreign providers. Member States should standardise customer due diligence expectations for minors and vulnerable clients where juvenile accounts are permitted with guardian controls. Clear rules are also required for source of funds verification given the presence of tax incentives and cash like flows.

Operational resilience, ICT risk and outsourcing

Operational requirements should leverage existing EU frameworks to avoid duplication and fragmentation. DORA should apply to ICT risk management, incident reporting, testing and oversight of critical third party providers, with specific attention to SIA specific digital features such as transfer portals and tax APIs to ensure they meet DORA standards. Rules on outsourcing to cloud and other third parties, cross border data flows and any localisation constraints should be clarified to avoid creating barriers for non domestic providers.

Data protection and client communications

Retail facing data processing must be lawful, transparent and comparable. Compliance with GDPR is required in respect of lawful basis, transparency, data minimisation and cross border transfers, including alignment of processing for tax pre fill and reporting with national legal bases. Disclosures and statements regarding costs, holdings, performance and tax status should be harmonised and presented in plain language, with multilingual provision to support cross border offerings.

Account portability, asset transfers and post trade

Facilitating switching is critical to competition and consumer outcomes. Member States should legislate a portability regime for accounts and portfolios that imposes clear time limits, low fees restricted to administrative costs and appropriate customer protections. Operational standards are needed for in specie transfers, continuity of corporate actions, carry over of cost basis and tax lots and processing of dividends and withholding taxes during transfers. Coordination with CSDR and custody models, whether direct or nominee and omnibus or segregated, is necessary in light of divergent national property law traditions that may affect title transfer and investor protections.

Cost transparency, fees and inducements

Cost structures significantly influence uptake and market dynamics. SIA specific transfer fees should be capped or otherwise constrained, with fee schedules presented in a transparent and comparable manner. Inducement rules should align with MiFID II, ensuring that fee structures do not undermine the policy intent of SIAs, for example by penalising passive or diversified investment strategies.

Marketing, distribution and complaint handling

Distribution rules must be consistent, proportionate and non discriminatory. Cross border marketing should be permitted in line with passporting, avoiding local approval hurdles for the SIA wrapper itself. Risk warnings, access to educational content and financial literacy materials should be standardised. Clear complaint handling and ADR/ODR pathways are necessary, including for cross border customers, to ensure effective redress.

Governance, supervision and reporting

Clarity on institutional responsibilities reduces friction and enhances accountability. The roles of competent authorities for SIA specific obligations should be clearly defined, including the home/host split and interaction with tax authorities. Monitoring and reporting should be established for uptake, assets and the budgetary impact of tax incentives, with mechanisms to share best practices and promote convergence over time. Supervisory coordination should be strengthened to avoid duplicative demands on cross border providers.

National divergences and anticipated friction points

Even with a shared blueprint, meaningful divergences are likely. Tax systems vary widely, so aligning deduction, deferral or exemption models and contribution caps will be challenging and may incentivise cross border provider arbitrage, particularly if portability is strong. Differences in civil and property law will affect custody and transfer mechanics. Language and disclosure requirements may become implicit barriers if not addressed through standardised formats and translations. Existing national schemes, such as equity savings accounts, may require grandfathering or migration pathways to avoid market disruption.

Member State considerations

In addition to the general considerations above, the critical execution risks/barriers to EU-SIA harmonisation and risk of 27+ national SIA fragmentation are tax architecture design, cross border access without gold plating, custody/property law differences affecting transfers and State aid sensitivities. Against that backdrop, the sections below set out targeted implementation considerations for each Member State.

Austria

Austria’s withholding based capital income taxation (KESt/Wertpapier KESt) simplifies retail compliance but can complicate deferral style incentives. An SIA framework should leverage withholding agents for pre filled returns while enabling passported providers to operate equivalent withholding or automated reporting. Alignment with strong consumer protection traditions argues for clear fee caps on transfers and explicit in specie portfolio portability. State aid risk is mitigated if incentives are structured as general measures and are asset neutral within eligible SIA scope. Coordination with the home supervisor under MiFID II and the host for SIA conduct conditions will be necessary to avoid duplicative oversight. 

Belgium

Belgium’s transaction tax (TOB), savings income regimes and the “Reynders tax” on fund gains require careful mapping to prevent SIA arbitrage across wrappers. A successful SIA should ensure neutrality among domestic and cross border UCITS/ETFs and bonds, with provider facilitated TOB collection or validated exemptions where applicable. The framework should allow non resident EU providers to mirror the same tax collection interfaces. Given multilingual consumer law, standardised disclosures and translations are essential to avoid de facto barriers. Account portability with administrative cost only fees and non taxable portfolio transfers should be codified. 

Bulgaria

With a developing retail market and improving digital onboarding, Bulgaria can prioritise simple flat or deferral style SIA tax incentives with robust anti abuse rules. Enabling remote know-your-customer (KYC) under national anti-money-laundering (AML) aligned with eIDAS improves access, including for EU passported providers. Property law and custody chain rules should expressly support omnibus safeguarding under MiFID II and continuity of corporate actions during in specie transfers. Clear coordination between the Financial Supervision Commission and the National Revenue Agency on pre filled returns will reduce friction. 

Croatia

Croatia should focus on streamlined tax treatment and pre filled compliance to build confidence in capital markets participation. To attract cross border offers, avoid local presence requirements or product lists favouring domestic issuers. Investor compensation scheme coverage and client asset segregation standards should be reaffirmed for SIA holdings, including for foreign providers using sub custodians. Harmonised disclosures in Croatian and English can support cross border distribution without additional approvals for the SIA wrapper. 

Cyprus

Given Cyprus’s established fund and securities services sector, broad provider eligibility and cross border parity should be straightforward. The SIA tax model should balance competitiveness with State aid constraints, using general measures accessible irrespective of provider location. Robust DORA implementation and outsourcing clarity for cloud based SIA portals will be key, as will GDPR compliant data sharing for tax pre fill. Account portability provisions should address both sale/repurchase and in specie paths without triggering tax. 

Czechia

Czechia’s long term investment product reforms provide a natural anchor for SIAs. Implementation should prevent overlap and investor confusion by mapping existing benefits into a general SIA architecture that is asset neutral and open to EU providers. Tax deferral or deduction mechanisms should include clawbacks for early withdrawals that are proportionate and easy to administer. Custody and Central Securities Depositories Regulation (CSDR) settlement practices should be leveraged to standardise in specie transfers and cost basis continuity. 

Denmark

Denmark’s retail friendly “Aktiesparekonto” experience offers a template for simple SIAs with capped contributions and simplified taxation. Extending equivalent treatment and operational rails to EU authorised providers will be pivotal to comply with the Recommendation. Ensure that inducement and cost transparency rules under MiFID II are applied consistently, with clear statements of transfer fees limited to administrative costs. Given high digital adoption, DORA compliant APIs for tax pre fill and portability would accelerate scale. 

Estonia

Estonia’s investment account and broader tax features support deferral style SIAs with straightforward reporting. Implementation should ensure that EU passported providers can integrate with Estonian tax reporting interfaces on equal terms. To avoid discrimination, encourage broad eligible assets across EU issuers and UCITS/ETFs while excluding highly complex instruments and non financial crypto assets. Insolvency and client asset segregation rules should be clarified for cross border custody chains. 

Finland

Finland’s equity savings account (osakesäästötili) provides operational lessons but is currently equity focused. An EU aligned SIA should widen eligible assets to include bonds and UCITS/ETFs and make the framework accessible to EU providers without extra licensing. Harmonised tax pre fill and explicit non taxable portfolio transfers will reduce switching costs. Finnish and Swedish language disclosures should be standardised to support cross border offers. 

France

France’s Share Savings Plan/ Share Savings Plan for the Financing of Small and Medium-Sized Enterprises (SMEs) and Mid-Caps (PEA/PEA PME) regimes are mature but geographically and asset type constrained. A compliant SIA should avoid EU issuer discrimination, broaden eligible asset classes and ensure parity for providers authorised elsewhere in the EU. Transfer mechanics from PEA and general securities accounts into SIAs will require transitional rules and cost basis carry over. Fee transparency and inducement governance should be tightened to prevent distribution bias against low cost diversified options. 

Germany

Germany’s “Abgeltungsteuer” simplifies collection but complicates deferral. An SIA could operate with provider withholding or comprehensive pre filled reporting, open to EU providers via recognised interfaces. Careful design is needed to avoid selective advantages that raise State aid concerns; general measures with contribution caps help. Given strong retail interest in ETF savings plans, neutrality across UCITS/ETFs and bonds is essential, alongside robust in specie portability and MiFID II safeguarding clarity. 

Greece

To foster uptake, Greece should centre SIAs on simple tax incentives and automated compliance, with robust anti abuse rules for early withdrawals. Cross border provider access must be preserved without local presence or product approval steps for the wrapper. Align consumer disclosures with PRIIPs and MiFID II and ensure translation standards that enable competition. Custody and insolvency frameworks should be reviewed to secure client assets and ensure portability continuity. 

Hungary

Hungary’s tax favoured long term accounts (e.g., TBSZ) inform SIA design but SIAs should be asset neutral and open to EU providers. Tax incentives can leverage deferral with clawbacks while protecting portability across providers and borders without tax events. AML/KYC rules should explicitly permit remote onboarding and foreign eIDs. Operational standards for in specie transfers and dividend processing mid transfer will support competition. 

Ireland

Ireland’s fund tax regime and ETF “deemed disposal” rules can create complexity; SIA design should prioritise provider facilitated tax computation and pre filled reporting, including for non resident EU providers serving Irish residents. Ensure neutrality across Irish domiciled and other EU UCITS/ETFs to avoid market distortions. Given a high prevalence of cross border providers, clear home/host supervisory delineation and portability protections will be critical. 

Italy

Italy’s Individual Savings Plan (PIR) experience shows strong uptake when tax incentives are simple and predictable. A new SIA should be broader in asset scope, avoid issuer location conditions that risk free movement issues and guarantee cross border provider parity. To encourage switching, codify non taxable portfolio transfers and cap transfer fees at administrative cost. DORA compliant interfaces for tax pre fill and incident reporting should be mandated across domestic and foreign providers. 

Latvia

Latvia’s investment account regime provides foundations for SIAs with deferral and simplified reporting. Implementation should explicitly recognise EU providers for tax data exchange and ensure eligible assets include UCITS/ETFs and bonds across the EU. Strong consumer disclosure rules and portability standards will build trust and competition. Investor compensation scheme coverage for cross border clients should be restated. 

Lithuania

Lithuania’s investment account framework supports deferral; an SIA overlay should be inclusive of EU wide products and providers, with clear exclusions of highly complex instruments. Tax pre fill and automated collection options should be extended to foreign providers on equal terms. DORA alignment for SIA digital rails and GDPR compliant data sharing with the tax authority are essential to scale participation. 

Luxembourg

Luxembourg’s sophisticated fund ecosystem argues for an SIA that is fully open to EU providers and neutral across EU products. To mitigate State aid risks, incentives should be general and asset neutral within the eligible set. Given cross border distribution, multilingual disclosures and robust portability across international custody chains must be standardised. Home/host supervisory coordination should avoid duplicative conduct oversight. 

Malta

Malta can accelerate SIA adoption through simplified tax incentives with clear anti abuse rules and seamless digital onboarding, accessible to EU passported providers. Custody and investor compensation provisions should be clarified for cross border sub custody models. To support competition, ensure non taxable in specie transfers and transparent, capped administrative fees. 

Netherlands

The Netherlands’ box based personal income tax framework requires a carefully engineered SIA to avoid distortions and ensure neutrality across asset classes. Provider facilitated tax calculations or pre filled reporting will be necessary, including for foreign providers. The SIA should reinforce MiFID II cost transparency and inducement controls and codify in specie portability with cost basis continuity and dividend processing safeguards. 

Poland

Poland’s Indywidualne Konto Emerytalne/ Indywidualne Konto Zabezpieczenia Emerytalnego (IKE/IKZE) wrappers can coexist with a broader, asset neutral SIA that is open to EU providers and supports automated tax compliance. Portability should be neutral for tax and allow in specie transfers with administrative only fees. Clear host/home supervisory delineation and strong AML/KYC provisions for remote onboarding will reduce friction. Consumer disclosures should be standardised and translated to facilitate cross border offers. 

Portugal

Portugal should favour simple, general tax incentives compatible with State aid rules and non discrimination across EU products and providers. Tax pre fill and provider collection should be available to foreign providers. Given existing long term savings products, transitional rules and mapping of benefits will help avoid fragmentation. Portability without tax events and DORA compliant digital rails will be essential to build trust. 

Romania

Romania can prioritise accessibility via low minimums and digital onboarding under AML/eIDAS, with equal treatment for EU providers. A flat or deferral style SIA tax incentive with clear early withdrawal rules would be administrable. Custody and client asset safeguarding under MiFID II should be codified for cross border chains and transfer standards should mandate in specie options and capped fees. 

Slovakia

Slovakia’s time based capital gains relief interacts with SIA incentives; guard against double relief by designing transparent, general measures and clear clawback rules. Ensure EU provider parity for tax interfaces and cross border marketing. Portability provisions should include time limits and operational continuity for corporate actions and dividend withholding mid transfer. 

Slovenia

Slovenia should adopt a broad eligible asset list and exclude complex instruments, ensuring equal access for EU providers. Provider facilitated tax reporting and pre fill will be necessary to simplify compliance. Codified in specie transfer rights with administrative only fees and MiFID II safeguarding assurances will support competition and uptake. 

Spain

Spain’s retail landscape would benefit from an SIA that is neutral across UCITS/ETFs, bonds and equities and that streamlines tax compliance through provider collection or pre filled returns, including for foreign EU providers. Avoid issuer location biases to remain consistent with free movement. Strong inducement controls, fee transparency and portability without tax events will be necessary to ensure effective competition. 

Sweden

Sweden’s investment savings account (ISK) and insurance based wrappers demonstrate the power of simplicity and predictable tax. An EU aligned SIA should preserve simplicity while extending cross border parity to EU providers and ensuring neutrality across eligible EU UCITS/ETFs and bonds. DORA compliant incident reporting and tax data interfaces, plus capped administrative transfer fees and guaranteed in specie options, will underpin portability.

Gaps if EU frameworks remain unchanged: specifically client assets and client money, investor compensation and financial ombudsman schemes

The EU-SIA’s blueprint (and indeed the EU’s CMU and SIU strategy overall) misses the opportunity to harmonise existing the following existing rules, each of which are subject to various degrees of fragmentation in how they are implemented and supervised.

Client assets, client money and collateral assets

Absent further EU level improvements, fragmentation in the treatment of client assets and client money will persist across Member States, particularly around segregation models (omnibus versus individually segregated), recognition of proprietary claims in insolvency and the status of client money (trust like versus debtor creditor) in civil law. Divergent rules on title transfer collateral arrangements, rehypothecation, interest on client money and record keeping/reconciliation cadence create legal uncertainty for cross border providers and complicate SIA portability, in specie transfers and corporate actions continuity. These divergences also interact with CSD and custodian practices in ways that can lead to settlement frictions, shortfall allocation disputes and inconsistent treatment of sub custodian failures.

For SIA users, unchanged rules increase the risk that identical portfolios face different protections depending on custody chain configuration and the investor’s or provider’s Member State. Providers may need to implement multiple control sets to satisfy local interpretations of MiFID asset safeguarding and collateral reuse, elevating operational cost and error risk. Where collateral is taken for credit, margin or securities lending linked to SIAs, varying encumbrance disclosure and consent standards could undermine transparency for retail investors and weaken comparability across offers, while gaps in cross border recognition of security interests may delay asset returns in stress.

Investor compensation scheme coverage

Without targeted reform of the Investor Compensation Schemes Directive framework, coverage will remain uneven in scope (comparably less to that of the Depositor Guarantee Schemes and indeed international peers), triggers, eligibility and payout timelines. Differences in ex ante versus ex post funding, monetary caps, netting rules and exclusions (e.g., professional clients, complex entity structures or losses stemming from market movements) will continue to yield variable outcomes for otherwise similar SIA clients. Cross border claims processing remains cumbersome due to language, documentation and home/host responsibility splits, which can be acute where custody chains or passported distribution blur the location of the failure and the competent scheme.

For SIAs, this heterogeneity weakens consumer confidence and may distort competition by favouring providers domiciled in jurisdictions with faster, better funded schemes, irrespective of underlying risk. Absent harmonisation on coverage boundaries (cash versus financial instruments held at intermediaries) and coordination with insolvency waterfalls, clients may experience delays or gaps in recovery even where segregation was observed, particularly in shortfall scenarios or when assets sit with failing sub custodians outside the client’s home state.

Financial ombudsman schemes

If current arrangements are left unchanged, material disparities in the remit, powers, monetary limits, binding effect and procedures of national financial ombudsman schemes will persist. Cross border jurisdiction and competence remain ambiguous for passported services, leading to forum and supervisory friction where home and host regimes differ on admissibility thresholds, time bars or the treatment of group complaints. These inconsistencies can lengthen redress timelines and raise costs for both consumers and firms, with limited mechanisms to ensure mutual recognition or enforcement of ombudsman outcomes across borders.

For SIAs distributed cross border, divergent alternative dispute resolution/online dispute resolution (ADR/ODR) pathways and language standards risk inconsistent consumer outcomes for identical fact patterns, potentially encouraging forum shopping or disengagement from redress altogether. The absence of EU level convergence on data sharing and publication of ombudsman decisions limits supervisory learning and market discipline, reducing incentives for providers to remediate root causes and undermining the comparability and trust needed for a single retail market.

Outlook and next steps

The Commission’s Recommendation on EU-SIAs represents a significant step towards a more integrated and inclusive EU retail investment market. Member States are expected to report on implementation measures and EU-SIA uptake as part of the SIU monitoring process, with a midterm review scheduled for 2027. Market participants should engage proactively with national authorities, align product offerings with the recommended standards and contribute to awareness and financial literacy efforts to support the successful rollout of EU-SIAs across the EU.

While the Recommendation is non-binding, its implicit directive for Member States to align national frameworks with the blueprint suggests a potent trajectory towards de facto harmonisation, albeit with inherent challenges. The primary hurdle will be the faithful and consistent transposition of the Recommendation's principles into national law, particularly concerning tax coordination and the seamless cross-border portability of EU-SIAs. Supervisory convergence, driven by the ESAs, will be critical in mitigating the risk of national gold-plating and ensuring genuine market integration, demanding a proactive stance from firms in anticipating and shaping these evolving standards.

For financial services firms, this initiative presents a significant strategic opportunity to expand their retail client base across the EU, provided they can effectively navigate the operational complexities of cross-border offerings and harmonised tax reporting. Early and strategic investment in scalable, digitally-enabled EU-SIA platforms, coupled with a deep understanding of evolving national interpretations, will differentiate market leaders. Ultimately, the success of the EU-SIA hinges on fostering consumer trust through transparent, competitive products and contributing to the broader objective of mobilising retail capital for the EU's long-term economic and sustainability goals.

In short, successful EU wide implementation of an EU-SIA will depend on designing nationally administered SIAs that fully respect EU level passporting and non discrimination, deliver genuine tax and administrative simplicity (including for cross border providers) and hard wire portability and asset protection.  Achieving that balance – while managing State aid, AML, DORA, GDPR and post trade realities – will determine whether SIAs scale across the EU rather than fragment into 27 incompatible variants.

About us

PwC Legal is assisting a number of financial services firms and market participants in forward planning for changes stemming from relevant related developments. We have assembled a multi-disciplinary and multijurisdictional team of sector experts to support clients navigate challenges and seize opportunities as well as to proactively engage with their market stakeholders and regulators.  

Moreover, we have developed a number of RegTech and SupTech tools for supervised firms, including PwC Legal’s Rule Scanner tool, backed by a trusted set of managed solutions from PwC Legal Business Solutions, allowing for horizon scanning and risk mapping of all legislative and regulatory developments as well as sanctions and fines from more than 2,500 legislative and regulatory policymakers and other industry voices in over 170 jurisdictions impacting financial services firms and their business.  

Equally, in leveraging our Rule Scanner technology, we offer a further solution for clients to digitise financial services firms’ relevant internal policies and procedures, create a comprehensive documentation inventory with an established documentation hierarchy and embedded glossary that has version control over a defined backward plus forward looking timeline to be able to ensure changes in one policy are carried through over to other policy and procedure documents, critical path dependencies are mapped and legislative and regulatory developments are flagged where these may require actions to be taken in such policies and procedures.   

The PwC Legal Team behind Rule Scanner are proud recipients of ALM Law.com’s coveted “2024 Disruptive Technology of the Year Award” as well as the “2025 Regulatory, Governance and Compliance Technology Award”. 

If you would like to discuss any of the developments mentioned above or how they may affect your business more generally, please contact any of our key contacts or PwC Legal’s RegCORE Team via de_regcore@pwc.com or our website.