3FOOD

Third Industrial Revolution Consulting Group
border). These regulations can contradict with the core objectives principles of the cloud or
lead to further inconsistencies.
5.4 Avoiding Fragmentation of Regulations
Currently the national consumer protection and contract laws differ throughout the 28 Member
States and companies usually need to act in accordance with the host countries’ national
consumer protection laws and supervisory measures. It is also true that the retail financial
services market is still fragmented due to culture/language barriers, divergences in national
taxation, civil law and product specifications defined by national regulations and consumer
needs which remain mainly local.
At present, inconsistent requirements in different countries are hampering innovation in new
services. Banks and consumers are not able to reap the full benefits of digitalization. This is
particularly the case regarding access to platforms, data privacy, cloud and big data.
5.5 Ensure the Right Conditions for Innovation to Thrive
Banks should be allowed to develop activities beyond traditional banking under the same
conditions as their competitors.
Considering the overall picture of how financial services are provided in the digital arena, it
is key to provide the right environment for banks to innovate.Banks planning to develop
activities beyond pure traditional banking (marketplaces, aggregators) or potentially
integrating FinTech companies into their business models, should not be constrained by the
obligation to consolidate any subsidiary or affiliated company within the regulatory scope of
the parent company owing to capital requirements, level of supervision, security and
liability.
The principle of “same services/risks, same rules” should apply to all companies
regardless of the sector or location.
A competitive and innovative EU Digital Single Market features safeguards regarding
consumer protection, trust and security. Fair trade and open competition on the market
enables consumers to access a range of new competitive products with higher
performance. It also enables companies to offer products to a broader array of customers.
To do so, the right competitive environment should be set and allow an open and fair
competition among the market players.
o Regardless of the sector: Because products and services will be under high pressure
to be supplied instantly, safely and with a guarantee of quality, the principle of
“same services/risks, same rules” should apply to all companies offering similar
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