EBF position on the Regulation revising the Cybersecurity Act (CSA2)

Brussels, 22 May 2026 – The European Banking Federation is publishing its position paper on the European Commission’s proposal for a Regulation revising the Cybersecurity Act, known as CSA2. The EBF supports the objective of simplifying and harmonising the EU cybersecurity framework, while ensuring proportionality, practical applicability and consistency across horizontal and sector-specific rules.

For the banking sector, the proposal’s new trusted EU ICT supply chain security framework should be predictable, transparent and aligned with the risk-based approach already established under the Digital Operational Resilience Act (DORA). The EBF calls for greater clarity on the methodology and governance for identifying high-risk suppliers, as well as on the geographical scope and practical impact of potential restrictive measures. Any restrictive or mitigating measures should be proportionate, based on feasibility and market-capacity assessments, and supported by adequate transition periods and exemptions or hardship provisions where no viable alternatives exist.

The EBF also supports a strengthened role for ENISA as a crucial part of the EU cybersecurity framework, including through continued support for all NIS2 sectors and strategic technological foresight. In parallel, European cybersecurity certification schemes should remain technical in nature, be developed through transparent stakeholder involvement, and be aligned with sector-specific requirements, including DORA, in order to support simplification and avoid legal uncertainty for certified products and services.

Read the full position

For more information please contact:

Alexandra Maniati, Senior Director of Innovation & Cybersecurity – a.maniati@ebf.eu

Raffaele Minicozzi, Senior Policy Adviser – Innovation & Cybersecurity – r.minicozzi@ebf.eu

About the EBF:
The European Banking Federation is the voice of the European banking sector, bringing together national banking associations from across Europe. The federation is committed to a thriving European economy that is underpinned by a stable, secure, and inclusive financial ecosystem, and to a flourishing society where financing is available to fund the dreams of citizens, businesses and innovators everywhere.