The EU’s 2025 Savings and Investments Union Strategy

RegCORE Client Alert | Capital Markets Union

QuickTake

On 19 March 2025, the European Commission (the Commission) unveiled its long-awaited Savings and Investments Union (SIU) strategy.Available here.Show Footnote Broadly speaking, the aim of the SIU is to enhance EU citizens’ wealth and bolster economic competitiveness across the European Union. This comprehensive strategy seeks to address – and pick up on previous initiatives including both pushes on the Capital Markets Union (CMU) as well as completing the Banking Union as well as feedback from the European Parliament, the European Council, the Eurogroup, the European Central Bank (ECB), which also reflect the reports proposed by Christian Noyer, Enrico Letta and Mario Draghi in April 2024 and September 2024 respectively.[See Client Alert here.]

As with past CMU efforts, the SIU aims to reduce the persistent fragmentation in EU financial markets, improve financial intermediation and increase retail participation in capital markets. In the current economic and geopolitical environment, the SIU strategy remains a pivotal step towards creating a more integrated and efficient financial system within the EU, with a strong emphasis on channelling funds currently held as bank deposits into capital market products, to also advance progress on sustainable finance and geopolitical resilience.

As explored in this Client Alert, while the SIU builds on the efforts delivered as part of the 2015 CMU Action Plan, the 2017 CMU Mid-Term Review and the 2020 CMU Action Plan, the 2021 and 2022 CMU Packages and the relaunch, as a SIU, in 2025 introduces a number of fully new legislative actions and policy measures. Stay up-to-date on our EU RegCORE website for further standalone coverage on the SIU’s specificities from a financial services legal and regulatory perspective, including what steps firms should take so as to position themselves strategically as the Commission rolls out the details on the SIU.

Key takeaways from the SIU strategy

The SIU strategy introduces a series of legislative and non-legislative initiatives designed to foster a more integrated and efficient financial system throughout the EU. These measures are intended to improve links between savings and investments to enable EU companies meet their capital needs as well as to increase access to options for returns for EU citizens on their long-term savings. Some of these were present in the CMU, some were advanced outside of CMU and are now being drawn into SIU, and others are brand new to SIU. This can be highlighted as follows:

• EU savings and investments accounts: the strategy proposes the creation of a European blueprint for savings and investment accounts, aimed at offering better returns and incentivising retail investors to engage more actively in capital markets. These accounts are designed to be user-friendly, with digital interfaces, preferential tax rates, and low-cost provider changes, encouraging investment in European companies and strategic priorities.
• Retail Investment Strategy (RIS): the EU RIS, which was adopted in May 2023, focuses on enhancing investor protection, ensuring value for money and simplifying disclosures to encourage greater retail participation in capital markets including an EU-label for basic and simple investment products. While having been advanced independently of the SIU, the Commission has stated that it will not hesitate the withdraw the RIS proposal if negotiations fail to meet the RIS’ intended objectives. Bringing the RIS into the fold of the SIU allows for greater cross-sectoral emphasis on the need for clear, understandable information and aims to avoid further fragmentation of EU capital markets, ultimately contributing to a more robust retail investment culture. Core components of the RIS include the May 2023 proposals for a (i) Regulation amending the PRIIPS RegulationSee legislative file here and further analysis available from our EU RegCORE.Show Footnote and (ii) Omnibus Directive on Retail on Investment Protection.See legislative file here and further analysis available from our EU RegCORE.Show Footnote A further area that remains in discussion in the Omnibus Directive are reforms to (a) more proportionate client categorisation,Specifically, this focuses on making the eligibility criteria for investors that are categorised as “professional investors” on request more proportionate. This change would make it easier for such investors to access and firms to provide products and solutions to those clients and reduce their compliance burdens. The amendments to the eligibility criteria include (i) reducing the wealth criterion from EUR 500,000 to EUR 250,000, (ii) adding a new criterion relating to relevant education or training and (iii) introducing the possibility for legal entities to qualify as professional upon request by fulfilling certain balance sheet, net turnover and own funds criteria.Show Footnote (b) tackling bias in advice process, (c) better suitability and appropriateness tests, (d) improving harmonised professional standards on training and qualifications of investment advisorsIn addition to moving specific requirements in ESMA’s guidelines on the knowledge and competence criteria that are expected of investment advisors to Annex V of the MiFID II Directive, which would then be introduced into national law, the reforms mandate a minimum requirement of ongoing professional development and training (PDT) of at least 15 hours each year – to align it with other sectoral legislation such as the Insurance Distribution Directive. To provide assurance to customers and NCAs, compliance with the Annex V knowledge and competence criteria and the annual PDT requirement will require an annual certificate.Show Footnote and (e) strengthening supervisory enforcement.
• Financial Literacy Strategy: Aimed at empowering citizens with the knowledge needed to make informed financial decisions, fostering an “investment savvy” culture across the EU. This strategy, which has been revitalised by the SIU, includes measures to raise awareness and improve financial literacy, particularly among women, young people, and other adults, who typically have lower financial literacy levels. The Commission’s SIU Communication also highlights that levels of financial literacy vary significantly between Member States and that a more coordinated effort on both EU and national levels will be required to raise the average across the EU. The Commission intends to adopt the new Financial Literacy Strategy by 3Q 2025.
• Contributions by retail investors to funding of EU priorities: The Commission intends to explore how to increase opportunities for retail investors to access suitable financial products that allow them to contribute to the funding of EU priorities by co-investing alongside public sector entities including but not limited to the European Investment Bank (EIB) Group, the European Stability Mechanism (ESM) and national promotional banks.
• Stimulating equity investments by institutional investors: The Commission has long been concerned that institutional investors, notably insurers and pension funds, are less active in markets or equity and certain alternative assets such as venture capital, private equity and infrastructure. To overcome some of this (in addition to changes highlighted in the bullets below), the Commission, by 4Q 2025 intends to stimulate equity investments by institutional investors by (i) specifying in the Solvency II Delegated Regulation the eligibility criteria for the favourable treatment of long-term investments in equity; (ii) providing guidance for the banking sector on the use of favourable treatment for investments for “legislative programmes” intended to ensure that these programmes are applied consistently across the Single Market;In the Q&A on SIU released equally in March 2025, the Commission clarified that “legislative programmes” are schemes established by binding legislation that provides both public and private financing options to businesses operating in specific sectors of the economy. Banks authorised supervisors to invest in equity assisted by eligible legislative programmes are intended to enjoy a (more) favourable treatment in their calculation of their capital requirements.Show Footnote (iii) clarifying how investment can comply with the “prudent person principle” applicable to pension funds; and (iv) addressing “any further undue barriers to equity investment by institutional investors”.
• Recommendations on auto-enrolment, pension tracking systems, and pension dashboards: The SIU strategy includes recommendations to promote best practices for auto-enrolment in pension schemes, pension tracking systems, and pension dashboards. These measures aim to increase participation in supplementary pensions and improve financial planning for retirement. Further recommendations are aimed to be released by 4Q 2025.
• Review of IORPs and PEPP: Comprehensive review of the frameworks for Institutions for Occupational Retirement Provisions (IORPs) and the Pan-European Personal Pension Product (PEPP) to increase participation in supplementary pensions and improve investment capacity. The review aims to address challenges such as market fragmentation, high fees, and regulatory restrictions, enhancing the ability of pension funds to invest in productive and innovative sectors within the European economy. Further recommendations are aimed to be released by 4Q 2025.
• Market Infrastructure Package: Legislative proposals to eliminate barriers and promote more integrated trading infrastructures, modernise the legislative framework, and ensure better quality of execution and price formation on EU trading venues. This includes leveraging new technologies like distributed ledger technology (DLT) and artificial intelligence (AI) to enhance market efficiency across financial market infrastructure (well beyond the existing DLT Pilot Regime) as well as tokenisation of financial and real world assets.
• EuVECA Regulation Review: Enhancing the European Venture Capital Fund (EuVECA) Regulation to make it more attractive for investors and fund managers by widening the scope of investable assets and strategies. The EuVECA Regulation Review aims to foster a more dynamic venture capital market, supporting innovative startups and scale-ups in key sectors such as AI, biotech, and cleantech. It should be noted that the CMU Action Plan, notably in 2020, advanced the review of the European Long Term Investment Funds (ELTIF) Regulation to channel more long-term financing to companies and infrastructure projects. EU policymakers have long sought that both ELTIF and EuVECA labels will be attractive labels for funds that benefit the Single Market.
• Securitisation Review: Simplifying the EU Securitisation Framework to enhance efficiency, transparency and prudential requirements for banks and insurers. The Securitisation Regulation was itself a flagship of the 2015 CMU Action Plan. The review, which was issued by the Commission in February 2025 with a call for evidence, focuses on making due diligence and transparency requirements more manageable while maintaining high standards of financial stability. Further amendments will be required to the Capital Requirements Regulation and Capital Requirements Directive as well as the Solvency II Directive and the Solvency II Delegated Regulation. Work on the 2025 Securitisation Review under the SIU will also reflect the outcomes of the call for evidence.See further details here and from our EU RegCORE.Show Footnote
• Investment exits: Measures to support exits by investors in private companies, possibly through multilateral intermittent trading of private company shares, are proposed to improve capital accessibility for smaller companies.

The SIU strategy emphasises the need to remove sources of fragmentation in EU capital markets, whether regulatory, supervisory or political as encountered on several initiatives in recent years. To now effectively overcome a deadlock on many ends, the SIU strategy proposes, by 4Q 2025 to release legislative proposals on:

• Consolidating trading and post-trading infrastructures: enhancing interoperability, interconnection, and efficiency of EU trading and post-trading infrastructures. This involves modernising the regulatory framework to accommodate new financial technologies and ensuring that market infrastructures can operate seamlessly across borders. The Commission intends to publish proposals by 4Q 2025 to address more integration of trading and post-trading infrastructures, in particular on trading market structures, central counterparties, central securities depositories, financial collateral and settlement.
• Further developing the asset management sector: Reducing operational barriers and costs for asset managers operating across multiple Member States and addressing national barriers and divergent practices that are burdensome to distribution of EU-authorised funds across the EU as well as operational realities affecting cross-border groups. The strategy aims to streamline regulations and reduce duplication of efforts, making it easier for asset managers to serve clients across the EU.
• Efficient supervision in the Single Market: Strengthening supervisory convergence tools and achieving more unified supervision of capital markets, including the potential transfer of certain tasks to the EU level is a key objective of the SIU. While this focuses on ensuring that all financial market participants should receive the same supervisory treatment in the EU’s Single Market regardless of their lobation, the Commission has (correctly) taken the view that divergences in supervision requires a new balance between mandates at the EU and national levels. The SIU communicates that:

o    the European Supervisory Authorities (ESAs) need to make better use of their existing supervisory convergence tools to achieve more integrated and harmonised supervision. While this is a (political) step back from the anticipated (and perhaps much needed move) for full Europeanisaiton as is the case in the Banking Union. The Commission intends to publish legislative proposals by 4Q 2025 to strengthen the efficacy of the ESA’s convergence tools and also calls on ESAs and national competent authorities (NCAs) to make full use of currently available tools and implement the simplification agenda as set out in its February 2025 communication “A simpler and faster Europe: Communication on implementation and simplification”;Available here.Show Footnote and

o    that the ESAs, within their mandate, develop more Europeanised supervisory powers and capacity in respect of (i) market operators with significant cross-border activities, such as certain large trading and post-trading infrastructures as well as cross-border asset management groups; and (ii) new or emerging sectors, such as crypto-asset services providers (CASPs).

Even if this approach does not move to full centralisation, it may still cause some resistance and accountability concerns from some national Member States and the existing mandates of national competent authorities (NCAs). This convergence, however, aims to ensure consistent application of rules and reduce the risk of supervisory arbitrage, fostering a more integrated and trustworthy financial market.

The SIU strategy also underscores the continued importance of an integrated EU banking sector and a complete Banking Union. To this end, the Commission’s communication sets out:

• Addressing shortcomings in crisis management and deposit insurance: urging co-legislators to agree on an ambitious outcome in the crisis management and deposit insurance framework negotiations. This includes establishing the long-awaited European Deposit Insurance Scheme (EDIS) to ensure a more resilient and integrated banking sector. Please visit PwC’s EU RegCORE for further in-depth thought leadership on the EU’s ongoing crisis management and deposit insurance (CMDI) efforts.
• Defending the international level playing field: Ensuring that EU banks remain competitive on global financial markets and reducing barriers to market integration. The strategy calls for vigilance in maintaining balanced regulatory standards that do not disadvantage EU banks internationally. 
  In delivering all of the above, the Commission intends to establish by 2Q 2025 a dedicated channel for all market participants to report encountered barriers within the Single Market so as to be able to step up enforcement action to accelerate the removal of barriers.

Over the longer-term, the Commission intends to publish a mid-term review or the SIU by 2Q 2027 that will report on the state of play on overall progress and reflect input received from stakeholders on the initial proposals for the SIU as well as how SIU has delivered against previous efforts to complete a CMU.

Key changes in the SIU when compared to the CMU Action Plans

The SIU is a next evolution from the Commission’s on-going efforts on CMU that it has delivered over the past decade even where certain items have remained incomplete in implementation.

When compared to the CMU 2020 Action Plan, the 2025 SIU strategy:

• introduces a more detailed and structured approach to financial literacy and retail investment strategies;
• proposes specific measures for savings and investments accounts, which were not explicitly mentioned in the 2020 Action Plan; and
• includes a more comprehensive review of IORPs and PEPP, whereas the 2020 Action Plan focused more on immediate post-crisis recovery measures.

When compared to the CMU 2017 Mid-Term Review, the 2025 SIU strategy:

• builds on the PEPP initiative by proposing a comprehensive review and enhancement of the framework;
• places a stronger emphasis on financial literacy and retail investor protection compared to the 2017 Mid-Term Review; and
• introduces new measures for savings and investments accounts and auto-enrolment in pension schemes, which were not covered in the 2017 Mid-Term Review.

When compared to the CMU 2015 Action Plan, the 2025 SIU strategy:

• introduces new measures for financial literacy, retail investment strategies, and savings and investments accounts, which were not part of the 2015 plan.
• proposes a more comprehensive review of pension frameworks (IORPs and PEPP) compared to the 2015 plan’s focus on immediate regulatory adjustments; and
• includes a detailed market infrastructure package to address barriers to integrated trading and post-trading infrastructures, which was not a focus in the 2015 plan.

The SIU’s legislative and non-legislative measures that are scheduled for publication and implementation in 2025 and on the road to 2027 are likely to have a number of implications for regulated firms. It remains to be seen whether the SIU can cut through some of the challenges that curtailed CMU’s efforts in the past decade.

Implications for regulated firms

The legislative actions proposed in the 2025 SIU strategy are likely to have several implications for regulated firms. Firstly, firms will need to adapt to new compliance requirements, particularly in areas such as financial literacy, retail investment strategies, and pension frameworks. The revision to existing as well as targeted introduction of new regulations and reporting requirements may necessitate some firms to updates their internal policies and procedures, as well as the documentation used with counterparties and clients. In certain areas, notably when it comes to changes to categorisation of clients as well as focus on training and qualifications of investment advisors. This will require significant investment in compliance infrastructure and training to ensure that all staff are aware of and adhere to the new standards.

Secondly, the SIU strategy emphasises enhanced investor protection standards, which will require firms to ensure that their products and services meet the new standards for transparency and value for money. This includes modifications to sustainability rules and the introduction of new disclosure requirements. Firms will need to review and possibly redesign their product offerings to align with these new standards, ensuring that they provide clear, understandable information to retail investors. This will also involve a reassessment of marketing and sales practices to ensure compliance with the new regulations.

Thirdly, the focus on innovation presents both opportunities and challenges for regulated firms. The SIU strategy highlights the importance of new technologies such as DLT and AI in enhancing market efficiency. Many firms may want to step up their investment in these technologies to remain competitive, but they will also need to navigate the regulatory landscape that governs their use. This will require a careful balance between innovation and compliance, ensuring that new technologies are implemented in a way that meets regulatory standards that continue to evolve in this space.

Finally, the SIU strategy aims to create a more integrated and efficient financial system within the EU, which will have significant implications for firms operating across multiple Member States. The reduction of barriers and the push for more unified supervision will streamline operations but will also require firms to navigate a new regulatory landscape. This includes greater (indirect as well as direct) centralisation of supervision in certain sectors and the potential transfer of certain tasks to the EU level. Firms will want to stay abreast of these changes and adjust their strategies accordingly to ensure compliance and take advantage of the opportunities presented by a more integrated market but mindful of expanding mandates at the ESA-level.

Outlook

The SIU strategy represents a significant step towards creating a more integrated and efficient financial system within the EU. By addressing the persistent fragmentation in EU financial markets and enhancing financial intermediation, the strategy aims to unlock significant untapped potential for growth, employment and wealth creation. The focus on sustainable finance and geopolitical resilience further underscores the EU’s commitment to maintaining its economic strength and strategic autonomy in a rapidly evolving global landscape.

As the strategy is rolled out, regulated firs will need to adapt to new legislative actions and policy measures, ensuring compliance while leveraging the opportunities presented by a more integrated and efficient EU financial system. The emphasis on financial literacy, investor protection, and market integration will be crucial in fostering a more robust and resilient financial environment, ultimately benefitting EU citizens and businesses alike.

The Commission’s commitment to continuous monitoring and engagement with stakeholders will be essential in ensuring the successful implementation of the SIU strategy. As the financial landscape evolves, firms must remain vigilant and proactive in navigating the regulatory changes and seizing the opportunities for innovation and growth.

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.

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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.