Neo-conglomerates and EU regul... Note

Neo-conglomerates and EU regulatory perimeter challenges – state of play and evaluation of policy options

This paper explores the implications of non-bank groups providing bank-like services, especially payment services, within the European Union. It addresses policy options for regulating these "neo-conglomerates" by recalibrating the regulatory perimeter. The paper utilizes five EU case studies to illustrate how financial services are delivered digitally through unbundling, re-bundling, embedded distribution, and white-label partnerships. These case studies map business models, licensing structures, fintech partnership chains, and data frictions. The analysis reveals how these factors can obscure group-wide risks and complicate supervisory cooperation between home and host authorities. The paper identifies potential regulatory blind spots and misalignments in existing prudential, conduct, and operational objectives. It also draws on guidance from standard-setting bodies regarding financial innovation, fintech, and Big Tech supervision. The research pinpoints four priority areas for consideration to limit regulatory arbitrage and systemic interdependencies. Simultaneously, the paper aims to preserve innovation within the evolving financial landscape. The ultimate goal is to ensure a robust and adaptable regulatory framework.