European Commission Publishes Its 2025 Financial Literacy Strategy

QuickTake

On 30 September 2025, the European Commission announced its new EU-wide Financial Literacy Strategy (EU-FLS) through a Communication and a Factsheet¹ during a press conference. This initiative addresses persistently low levels of financial literacy² across Member States, as evidenced by the 2023 Eurobarometer survey.³ The EU-FLS aims to empower citizens, foster financial inclusion and enhance economic resilience.

The Commission's Communication is a significant soft law instrument that will shape supervisory expectations and market practice across the retail financial ecosystem. While non legislative in itself, especially as education remains a purely Member State and not an EU-level competence, the EU-FLS is a central component of the broader Savings and Investments Union (SIU) agenda. It complements existing regulatory and supervisory frameworks, including the Retail Investment Strategy (RIS).⁴ Ultimately, the Communication establishes a clear policy direction for Member States, the European Supervisory Authorities (ESAs)⁵ and industry engagement starting in 2026.

This Client Alert assesses the contents of the EU-FLS Communication. It also examines the key legal, regulatory and supervisory expectations arising from future efforts by the ESAs, national Member States and respective national competent authorities (NCAs), particularly given known Member State specifics. This Alert should also be read in conjunction with further analysis on the European Commission's 30 September 2025 announcements, which advocate for the EU-wide introduction of harmonised savings and investments accounts (EU SIAs) and address the European Accessibility Act.

Rationale and key objectives of the EU-FLS

The EU-FLS recognises financial literacy as a critical life skill. This encompasses the awareness, knowledge, skills, attitudes and behaviours necessary for sound financial decision making. Low financial literacy correlates with inadequate savings buffers, higher vulnerability to financial shocks, increased exposure to fraud and scams and limited participation in capital markets. According to the 2023 Eurobarometer, only 18% of EU citizens are highly financially literate with significant disparities across Member States and demographic cohorts. The Commission's EU-FLS approach is therefore tailored to diverse needs, focusing particularly on women, youth, older people and those with lower incomes or education levels. It stresses 'teachable moments' to improve behavioural outcomes.

The EU-FLS's overarching objectives are to:

1. Raise awareness, promote access and ensure effective use of financial services;
2. Strengthen economic resilience and financial inclusion, including trustworthy debt advice;
3. Deepen investment literacy and understanding of real risk return trade-offs and diversification;
4. Support informed participation in capital markets, including via SIAs; and
5. Reduce financial inequality and foster long term financial wellbeing across demographic groups.

The EU-FLS builds on joint EC/OECD/INFE competence frameworks for adults, children and youth. It complements the RIS proposals for Member State level literacy promotion and interlocks with the EU's Digital Decade skills agenda, the 2025 Union of Skills Communication and SIU monitoring. It also responds to 2024 Council Conclusions calling for the exchange of best practices, continued monitoring and support for non legislative actions, leveraging ESA, ECB and OECD workstreams.

The EU-FLS' key structural components and strategic pillars

The EU-FLS includes the following key structural components:

• A curated exchange of best practices across Member States, with ministerial level stock takes from 2027;
• A voluntary EU Code of Conduct for private and not for profit providers of literacy initiatives (targeted for Q1 2027);
• ESA hosted repositories of financial education initiatives, expanded and made searchable;
• An EU level awareness campaign and a network of national "financial literacy ambassadors" (from 2026);
• Systematic monitoring (Eurobarometer 2027 onward) and inclusion of financial literacy in the European Semester, potentially leading to country specific recommendations; and
• Consolidation of funding visibility (Erasmus+, ESF+, SMP, TSI) and encouragement to use EC/OECD INFE competence frameworks.

In delivering these components, the EU-FLS's approach revolves around four interrelated pillars designed to add EU level value through coordination, communication, monitoring and funding. These can be summarised as follows:

1. Coordination and best practices

The Commission will facilitate regular thematic meetings among government expert groups. These meetings will coordinate communication, awareness, monitoring, evaluation and funding of financial literacy initiatives. Prioritising the identification and exchange of best practices, they will focus on targeted thematic areas such as teacher and trainer development, financial inclusion and tailored support for vulnerable groups, using a 'teachable moments' approach. The Commission will work with stakeholders to define thematic priorities and will organise exchanges among Member State experts from Q4 2026, elevating discussions to technical and political levels. Each Member State will evaluate the implementation of identified best practices; the Commission will then publish the outcomes.

A voluntary, principle based European Code of Conduct for private and not for profit organisations delivering financial literacy initiatives will be developed by Q1 2027. This Code aims to ensure transparent objectives, accuracy, neutrality and ethical standards, while mitigating conflicts of interest and promoting accountability and continuous improvement. Member States are encouraged to embed this Code within national strategies and to track adherence.

Regular workshops will convene private sector and not for profit stakeholders, including consumer and retail investor associations. These gatherings will foster a pan European community of practitioners, improve coordination and crystallise guiding principles for cooperation. At the supervisory interface, the Commission welcomes ESA work on financial education repositories and calls for a broader, user friendly and searchable repository across all supervised sectors.

Ministerial level stocktakes will be held biennially from 2027 to maintain political momentum, align with broader EU policy objectives and reinforce ownership at national level.

2. Communication and awareness raising

An EU wide communication and social media campaign will launch from 2026. It will target youth, children and vulnerable groups, promoting personal finance skills such as budgeting, retirement planning, debt management, risk management and fraud and scam prevention. The campaign will be flexible to support tailored national approaches and leverage local infrastructures and trusted interlocutors, including community centres and social partners, to reach hard to access groups.

A network of 'financial literacy ambassadors' will be established by Q1 2026. Each Member State will select reputable public figures to champion financial literacy, guide citizens to reliable resources and engage audiences across mainstream and social media, including hard-to-reach rural communities. The Commission will convene ambassadors periodically, equip them with adaptable materials and encourage collaboration with consumer and investor associations. Ambassadors will also be mobilised around Global Money Week and other relevant events.

Public events led or supported by the Commission will promote investment and financial literacy. These events will use inclusive materials to explain participation in capital markets, key product features and the benefits and risks of instruments, including SIAs, supporting the SIU's objective of fostering an "investment culture."

3. Monitoring progress and assessing impacts

The Commission will conduct a second Flash Eurobarometer survey on financial literacy in 2027 and repeat it regularly thereafter to track progress within a consistent framework. This survey may potentially expand question sets to cover budgeting, savings, retirement preparedness, resilience and insurance coverage, with gender and age lenses. Member States are encouraged to participate in international surveys and to deploy robust evaluation tools, including through the Commission's Learning Lab, the EIT's monitoring methodologies and OECD resources.

Monitoring will extend to implementing best practices and adherence to the Code of Conduct, with reporting to the Eurogroup in an inclusive format as part of the SIU Monitoring Framework. Financial literacy continues to feature within the European Semester. Country reports will assess developments using Eurobarometer data, informing potential country specific recommendations where warranted.

4. Funding for financial literacy Initiatives and research

The Commission will establish a dedicated website by Q4 2026 providing a consolidated overview of EU funding channels for financial literacy initiatives and research. Member States are encouraged to leverage Erasmus+, the European Social Fund Plus, the Single Market Programme and the Technical Support Instrument under the current Multiannual Financial Framework (MFF) and to improve the visibility of national funding sources.

Academic and policy research is encouraged to evaluate national strategies, identify cross border best practices and support the implementation of EC/OECD INFE competence frameworks by developing and testing competence based materials. The Commission will promote the use of competence frameworks in projects seeking EU funding and anticipates financial literacy measures being supported under National and Regional Partnership Plans aligned with SIU objectives.

Stakeholder engagement and implications for regulated firms

The EU-FLS emphasises collaboration among Member States, EU institutions, the ESAs, the ECB, consumer and retail investor associations, social partners, industry, civil society and international organisations such as the OECD. It seeks to complement and reinforce national strategies and initiatives, recognising consumer associations as trusted independent advocates, industry associations as scalable channels for expertise and outreach and trade unions as uniquely positioned for workplace education on retirement preparedness and other needs.

The Commission will support a pan European network of practitioners, encourage Member State adoption of the European Code of Conduct and use regular reporting and feedback loops to refine the EU-FLS. ESA hosted repositories of financial education initiatives are to be expanded and made searchable to enhance cross border consistency and learning.

Although EU and national measures under the EU-FLS are formally addressed to public authorities and non legislative actors, the strategy will influence supervisory expectations for various regulated firms. This includes banks, insurers, pension providers, investment firms, payment service providers, asset managers and FinTechs. The direction points towards demonstrable client understanding, neutral and unbiased 'educational' content, robust conflict management and measurable outcomes.

Supervisory monitoring will likely be underpinned by recurring EU wide surveys and national measurement frameworks. Authorities will look for demonstrable improvements rather than just activity counts. Firms that can evidence better customer outcomes – such as reduced complaints linked to misunderstanding, improved retention driven by informed decision making and lower fraud victimisation – will be well-positioned in supervisory dialogues. They may also enjoy greater forbearance where controls are otherwise sound. A strengthened focus on customer vulnerability and inclusion should also be expected. This will encompass accessibility features, including language options and disability accommodations, as well as credible financial inclusion pathways through basic accounts, affordable credit and microinsurance, often in partnership with community actors. Educational materials should be tailored to age, income and digital literacy profiles to ensure reach and effectiveness. This is likely to translate into the following implications for regulated firms:

First, product governance and distribution strategies will be assessed not only for formal compliance but also for outcomes. Supervisors are likely to expect evidence that disclosures, design choices and onboarding journeys reflect actual client comprehension and behavioural responses, with greater attention to vulnerable customers and accessibility features, beyond just formal compliance. Readability and usability testing, as well as scenario based explanations of risk/return and diversification – particularly in relation to SIAs – should become standard practice.

Second, firms engaging in financial literacy activities must treat 'education' as a governed content category. The forthcoming voluntary Code of Conduct implies heightened scrutiny of neutrality, accuracy and use of a non promotional tone. Firms should separate education from marketing, implement remuneration neutrality for staff delivering education, adopt clear signposting where content is promotional and maintain robust review and approvals through Compliance and Legal, aligned with the EC/OECD INFE competence frameworks.

Third, conflict of interest controls will need to address "education washing". Any biased material risks being treated as marketing within conduct and inducement regimes. Partner selection and due diligence for co delivery with non-governmental organisations (NGOs), schools or social partners should be formalised through written agreements setting roles, branding standards, complaint routes and data use.

Fourth, fraud and scam prevention must be integrated with digital channels, strong customer authentication (SCA) and transaction monitoring programmes. Supervisors will expect proactive customer education on phishing, social engineering and authorised push payment fraud, as part of broader resilience objectives.

Fifth, data protection obligations apply to literacy programmes and evaluations. Firms should implement purpose limitation, data minimisation and retention limits. They must also conduct data protection impact assessments (DPIAs) where behavioural analytics or outcome tracking are used. Records of materials, approvals, attendance and outcome metrics should be maintained to support supervisory dialogue and demonstrate effectiveness, for example, via reductions in misunderstanding related complaints, improved retention from informed choices, or reduced fraud losses.

Finally, cross border groups should harmonise educational standards and translations with local tailoring. They should prepare inventories for ESA/national repository submissions. Engagement with national programmes and ambassadors will be visible, increasing reputational stakes and the need for credible neutrality.

In many ways, firms may want to prepare a concise EU-FLS readiness checklist which includes:

• Map existing "education" and "guidance" content against neutrality and accuracy criteria; remediate where needed;
• Establish a group wide policy and controls for financial literacy activities, including separation from sales and remuneration neutrality;
• Align client facing materials with competence frameworks; embed plain language risk/return and diversification explanations in onboarding and SIAs;
• Enhance scam prevention education within digital channels; track fraud related outcomes as part of conduct of business management information;
• Prepare for ESA/national repository participation; catalogue initiatives and materials for submission and supervisory review;
• Build evaluation metrics and dashboards linking education efforts to outcomes (complaints, suitability exceptions, fraud incidents, retention);
• Coordinate with national associations and consumer groups to co deliver unbiased programs; document conflict management and partner governance; and
• Review data protection controls and consents for literacy programs and any related analytics.

Digitalisation and scam prevention are explicit pillars of the strategy. Supervisors are likely to expect proactive and ongoing customer education about phishing, authorised push payment fraud, social engineering threats and safe use of digital channels. This educational effort should integrate with strong customer authentication and transaction monitoring programmes, ensuring a coherent control environment rather than standalone initiatives. As the ESAs curate repositories and the Commission advances common frameworks, cross border groups should harmonise educational standards and translations subject to local tailoring, while maintaining consistent governance and quality thresholds across jurisdictions.

Running or co sponsoring literacy initiatives will entail processing participant data and tracking outcomes. Firms should therefore embed General Data Protection Regulation (GDPR) compliance into programme design, with clear purpose limitation, transparent notices and, where behavioural data informs evaluation, data protection impact assessments. The boundary between education and marketing also poses conduct and litigation risks. If educational content or delivery steers customers towards higher margin products, firms risk mis selling exposure. Strong internal controls, clear disclaimers and robust adherence to neutrality standards are essential. Reputationally, participation in visible national campaigns will attract scrutiny. Perceived bias or commercialising education can prompt criticism from consumer groups and supervisory intervention. Balanced against these risks is a strategic opportunity: Firms that deliver credible, unbiased educational tools can differentiate on trust, reduce complaints and churn and support safer adoption of long term savings and investment products. Constructive policy engagement can further shape the voluntary code of conduct and best practice repositories to be both pragmatic and scalable.

Boards should exercise explicit oversight by approving a financial literacy engagement policy aligned with the firm's conduct risk appetite and consumer duty objectives. That policy should set content standards covering neutrality, accuracy, readability and accessibility and should require pre clearance of all materials by the Compliance and, where appropriate, Legal department. Recognised competence frameworks, such as those developed by the European Commission and OECD INFE, should inform content structure and learning objectives. To manage conduct risk, firms should ensure a strict separation between educational sessions and sales processes, prohibiting product recommendations in educational contexts and applying remuneration neutrality for staff acting as trainers.

Where programmes are delivered with third parties, firms should conduct proportionate due diligence on NGOs, schools, trade unions and community partners to assess independence and quality. Written memoranda of understanding should define roles, data use, complaints handling and branding rules. Robust recordkeeping is critical: Firms should maintain inventories of educational materials, approval logs, attendance records and outcome metrics. Programmes should be periodically evaluated using a mix of knowledge assessments, complaint trend analysis and scam loss data, with findings feeding back into programme design. A deliberate focus on vulnerable customers is essential. Programmes should be tailored to specific demographics and provide disability accommodations, multiple languages and offline access points. From a data protection perspective, firms should provide clear notices, collect only data necessary for delivery and evaluation, apply appropriate retention limits and conduct impact assessments where behavioural analytics are used.

The EU-FLS directs Member States to promote financial literacy and supervisors are likely to translate this into concrete expectations for firms. As discussed above, firms should anticipate requests to support national literacy programmes, adopt recognised competence frameworks within client facing tools and avoid practices that could undermine literacy goals, such as pushing complex products to unsuited customer cohorts.

In parallel, the Commission's ambition to cultivate an 'investment culture' will shape supervisory expectations around SIAs and analogous product wrappers. Firms should expect national campaigns and ensure their customer materials explain risk return trade-offs, diversification principles and cost impacts in plain language, with scenario based education embedded in onboarding journeys.

Member State specifics: Potential challenges

Introducing the EU-FLS at the national level is legally feasible (even if education is a strictly national competence) but institutionally complex. The main hurdles are not in EU law but in domestic constitutional competences, neutrality and consumer protection norms, procurement and data protection constraints. Additionally, in many Member States, the EU-FLS needs to integrate with existing and, in parts, mature national ecosystems.

The most frequent points of friction across the EU27 Member States for consistently implementing the EU-FLS (as opposed to fragmenting it) include: Constitutional division of powers over education, demarcation between neutral education and marketing/regulated advice, public procurement and State aid constraints when partnering with private bodies, GDPR compliant evaluation and monitoring (particularly for minors and vulnerable groups), multilingual delivery and accessibility standards and alignment with mature national initiatives without diluting trusted domestic efforts.

In several Member States, education policy and curricula are constitutionally reserved to regional entities or are tightly guarded by national education ministries. Embedding competence frameworks or rolling out school based programmes requires formal cooperation with education authorities, often via lengthy curriculum processes and teacher training pipelines. Using extra-curricular delivery may mitigate national roll-out challenges.

Moreover, where financial supervision sits with separate bodies (central banks/market regulators), new coordination layers are needed to deliver the EU-FLS in conjunction with education authorities. In summary, the practical challenge is alignment without duplication, preserving trusted national brands and clarifying roles in multi agency committees.

The following national specificities in Germany and other EU Member States may present roll-out challenges for the EU-FLS's objectives and harmonisation aims:

Germany

In Germany, education is a state level competence exercised by the 16 Federal States (Länder). Embedding competence frameworks or school programmes typically requires consensus via the Standing Conference of the Ministers of Education (Kultusministerkonferenz), with differing priorities and timelines across states. The multi agency landscape, including the Federal Financial Supervisory Authority (Bundesanstalt für Finanzdienstleistungsaufsicht, BaFin), the Deutsche Bundesbank, consumer protection authorities and numerous foundations, already operates a range of initiatives. Therefore, any EU Code of Conduct or ambassador network should align with these actors to avoid perceptions of federal overreach. Industry participation must be structured to prevent conflicts of interest, with strict content controls, no inducements and clear separation from marketing to comply with consumer protection and rules on unfair commercial practices. High expectations under Germany's Federal Data Protection Act (Bundesdatenschutzgesetz, BDSG) and the EU's GDPR – often with works councils involved for workplace programmes – mean that data protection impact assessments, data minimisation and local data hosting may be needed for surveys and outcome tracking. Use of public funds or public private partnerships will trigger rigorous public procurement procedures and sponsorship transparency obligations, which may slow rollout.

Austria

Austria operates a national financial literacy strategy with an existing code of conduct. The key challenge is likely to be in aligning the EU's voluntary code and best practice repository with the national framework without creating parallel obligations or confusion. The social partnership model – anchored by the Austrian Federal Economic Chamber (Wirtschaftskammer Österreich, WKO), trade unions and the central bank – requires consensus based governance, so EU level ambassadors should fit within this corporatist structure and avoid perceptions of politicisation. While education is more centralised than in Germany, curriculum adjustments and teacher training still require formal processes through the Federal Ministry of Education, with lead times that may not match EU campaign calendars. Austria actively uses EU funding instruments, making it important to avoid duplication and to ensure procurement and grant rules support robust evaluation.

Belgium

Education and cultural content are the responsibility of the Flemish, French and German speaking Communities, while the national Financial Services and Markets Authority (Autorité des services et marchés financiers/Autoriteit voor Financiële Diensten en Markten, FSMA) leads financial education initiatives. Implementation requires buy in at Community level, alignment with existing FSMA programmes and consumer organisations and delivery in Dutch, French and German. Procurement and grant rules differ across federal, regional and Community levels, complicating consistent evaluation and scaling. For schools, the processing of pupil data must comply with Community education data policies in addition to the GDPR.

Bulgaria

Centralised governance facilitates policy alignment, but execution capacity varies by region. Concentrated markets heighten conflict of interest risks when partnering with industry and co funded outreach may trigger public procurement and State aid analysis. School based surveys must be supported by data protection impact assessments and clear data retention and anonymisation policies to comply with the GDPR.

Croatia

Croatia's centralised structures support integration, but regional disparities and school capacity constraints limit rapid curriculum adoption, making extra curricular pathways a pragmatic option. Management of EU funds requires advance planning for procurement and grant administration. Active consumer protection enforcement means messaging should avoid any perception of product promotion. Monitoring should rely on aggregated reporting to safeguard privacy.

Cyprus

Centralised governance can enable quicker adoption yet market concentration increases conflict of interest risks when industry partners deliver content. Materials should be tailored for conscripted youth and expatriate communities. Where tools are hosted outside Cyprus, cross border data flows must be addressed under the GDPR and public procurement rules will apply even for small contracts given the limited pool of suppliers.

Czechia

The Czech National Bank and education authorities coordinate ongoing financial literacy initiatives, so EU level measures should integrate with existing efforts and avoid duplication. Strict rules on advertising and unfair commercial practices constrain private sector roles and require clear separation from any promotional activity. Procurement and performance based funding models call for rigorous ex ante evaluation plans. For school based monitoring, data minimisation and anonymisation are expected.

Denmark

Although Denmark is a unitary state, municipal and school level autonomy means integration will rely on soft law instruments and strong teacher training support. The Danish Financial Supervisory Authority (Finanstilsynet) enforces strict advertising rules, requiring any private sector participation to be clearly separated from sales. Digital classroom tools face high expectations for data protection impact assessments. Given a high baseline of financial literacy, there will be close scrutiny of value for money and the incremental benefit of EU level campaigns.

Estonia

A digital first environment creates high expectations for cybersecurity, accessibility and privacy by design in programme delivery. In a relatively small market, private sector participation should be governed by a stringent code of conduct to manage conflicts of interest. Minority language outreach is sensitive and requires neutral, high quality translations. Digital platform procurement must align with national interoperability frameworks, such as the X Road platform.

Finland

Bilingualism in Finnish and Swedish, as well as Sámi language rights, requires inclusive content and translation standards. Interfaces with social welfare systems, such as the Social Insurance Institution (Kansaneläkelaitos, Kela), offer teachable moment channels but necessitate careful governance of data sharing and consent. The National Agency for Education manages curricula on long cycles, making extra curricular pathways pragmatic for near term progress. Finland's strong evaluation norms require credible methodologies and privacy preserving analytics.

France

France operates a centralised but protective model, with the Banque de France's EDUCFI initiative, the Financial Markets Authority (Autorité des marchés financiers, AMF) and the national education system delivering structured programmes. New EU branding or ambassador initiatives should not undermine established national brands or governance. France has tightened rules on financial promotions and the use of influencers for financial products, so an ambassador network must clearly separate roles, content and compensation from any promotional activity. Educational content must be strictly neutral and secular and materials that could be seen as encouraging investment – particularly in higher risk products – are likely to face resistance. The data protection authority (Commission nationale de l'informatique et des libertés, CNIL) requires robust data protection impact assessments for large scale surveys or profiling and national evaluation standards may conflict with EU level metrics unless co designed.

Greece

The Bank of Greece, the Hellenic Capital Market Commission (HCMC) and education authorities are developing capacity, with institutional constraints and curriculum timelines posing key bottlenecks. EU funded procurement can be lengthy and evaluation expertise is still maturing. Messaging should be calibrated to sensitivities around household debt and scams. For youth and rural outreach, careful consent mechanisms and data minimisation are necessary to meet GDPR expectations.

Hungary

Centralised decision making can enable rapid adoption but may be perceived as politicised unless ambassador networks are demonstrably non partisan. Industry participation should observe strict boundaries between education and promotion to manage conflicts of interest. Evaluation capacity is uneven and public procurement can be protracted. Data protection measures, including data protection impact assessments and strict minimisation, are necessary, especially for minors and vulnerable groups.

Ireland

Ireland operates a coordinated national framework involving the Department of Finance, the Central Bank of Ireland, competition and consumer authorities and education stakeholders. A robust regime for financial advertising and consumer protection requires a clear separation from product marketing and inducements. Any EU ambassador network should align with national media codes and norms on political impartiality. School based initiatives demand conservative data minimisation and detailed data protection impact assessments.

Italy

Delivery remains fragmented with regional divergence despite a national committee for financial education (Comitato Edufin) and established portals; capacity gaps are more pronounced in the South, complicating consistent national scaling of EU campaigns. Multiple authorities, including the Ministry of Economy and Finance (Ministero dell'Economia e delle Finanze, MEF), the Bank of Italy (Banca d'Italia), the securities regulator (Commissione Nazionale per le Società e la Borsa, CONSOB), the insurance supervisor (Istituto per la Vigilanza sulle Assicurazioni, IVASS), the pension funds supervisor (Commissione di Vigilanza sui Fondi Pensione, COVIP) and the education ministry, play roles, so clear ownership of ambassadors, code of conduct adoption and monitoring is essential to avoid duplication and turf issues. Curriculum overload and limited teacher training capacity can slow integration of competence frameworks, even as elective content. Content neutrality is critical, with governance around conflicts of interest, inducements and content vetting subject to close scrutiny. The Data Protection Authority (Garante per la protezione dei dati personali) has strict positions on children's data and large scale surveys, which can constrain granular, outcomes based monitoring unless appropriately minimised and anonymised.

Within the Autonomous Province of Bozen/Bolzano (South Tyrol), special statute autonomy and a trilingual school system (German, Italian and Ladin) place curricular decisions, teacher training and approvals with provincial education directorates for the three language streams. Moreover, media consumption and professional networks have strong ties to Austria and German language resources. Content standards and neutrality expectations often mirror German/Austrian norms, so EU branding and any ambassador model should be calibrated to avoid perceived commercialism and to fit local expectations. EU initiatives should be co designed with the Province, guarantee full multilingual delivery and calibrate branding and any ambassador roles to strict neutrality and a clear separation from promotion.

Latvia

Effective delivery requires practical bilingual provision in Latvian and minority languages with careful neutrality and quality control. Capacity constraints in schools and municipalities make teacher training and ready to use resources critical. Procurement and EU fund absorption should be sequenced coherently to avoid fragmented pilots. Data protection scrutiny is elevated for minors and any profiling used to assess behavioural change.

Lithuania

Centralised governance enables alignment, though regional capacity varies. Initiatives led by the Bank of Lithuania provide an anchor, so EU branding should complement rather than displace trusted domestic portals. Strict neutrality is needed to separate unbiased education from anything that could be construed as product promotion. Evaluation ambitions should match statistical capacity and use GDPR compliant designs.

Luxembourg

Luxembourg's small, multilingual market requires materials in Luxembourgish, French and German. The financial sector supervisor (Commission de Surveillance du Secteur Financier, CSSF) and the central bank already coordinate initiatives, so EU branding should be additive and avoid overshadowing national visibility. Market concentration heightens perceived conflicts when industry participates and procurement or State aid issues may arise when there are few providers. A large cross border workforce complicates both targeting and evaluation design.

Malta

Centralised structures enable nimble coordination among the Malta Financial Services Authority (MFSA), the Central Bank of Malta (CBM) and education authorities, but a small provider base raises neutrality concerns regarding industry participation. Maltese/English bilingual content promotes access but requires consistent quality assurance. Given small population sizes, monitoring should emphasise anonymisation and aggregation to preserve comparability while mitigating re identification risks.

Netherlands

The Money Wise platform (Wijzer in geldzaken), coordinated by the Ministry of Finance with De Nederlandsche Bank (DNB) and the Authority for the Financial Markets (AFM), anchors a mature national ecosystem. EU measures should avoid duplication and brand dilution while accommodating any EU code of conduct. The AFM enforces a strict separation between education and commercial promotion, necessitating tight governance of private sector involvement. A strong evaluation culture means EU metrics should map to domestic key performance indicators to gain acceptance. Data protection expectations are high, especially for minors, requiring robust data protection impact assessments and data minimisation.

Poland

A complex governance landscape involving the Polish Financial Supervision Authority (Komisja Nadzoru Finansowego, KNF), the National Bank of Poland (Narodowy Bank Polski, NBP), the education ministry and NGOs requires clear coordination amid strong consumer protection sensitivities. Formal, multi year curriculum processes suggest that extra curricular and workplace channels are more feasible in the near term. Formalistic public procurement rules apply and State aid considerations may arise with industry involvement. Active data protection enforcement calls for conservative approaches to youth data and engagement with parents.

Portugal

Portugal's National Plan for Financial Education (Plano Nacional de Formação Financeira, PNFF), led by Banco de Portugal (BdP), the securities regulator (Comissão do Mercado de Valores Mobiliários, CMVM) and the insurance supervisor (Autoridade de Supervisão de Seguros e Fundos de Pensões, ASF), is well established and branded, so EU alignment should avoid duplication. Formal procurement processes and multi annual budgeting can slow adoption of new EU linked projects. Delivery should account for differing school capacities and digital inclusion gaps across regions. Data protection expectations are manageable but call for upfront data protection impact assessments for outcome based monitoring.

Romania

A broad institutional set up and regional disparities complicate national consistency and curriculum integration tends to be slow, making teacher resources and teachable moment channels especially important. Procurement and budget cycles can delay implementation and evaluation workstreams. Data protection enforcement has intensified, so methodologies involving minors should be conservative and thoroughly documented.

Slovakia

Centralised governance coexists with limited capacity, making teacher training and resource provision key bottlenecks. Procurement is process heavy, particularly for EU funded initiatives and regional disparities require careful structuring of partnerships with municipalities to avoid conflicts and ensure consistent quality. GDPR oversight is close for education data sets, necessitating strong compliance controls.

Slovenia

In a coordinated small market, with Banka Slovenije and the securities regulator as anchors, alignment with EU initiatives can be swift. However, a limited provider base increases conflict of interest risks for private partners. In some municipalities, bilingual obligations in Slovene, Italian and Hungarian may require tailored materials. Outcome based evaluation should be proportionate to small sample sizes to mitigate re identification risks.

Spain

Spain's education system is devolved to the autonomous communities, requiring content in Spanish and co official languages such as Catalan, Basque and Galician, which increases approval steps, translation needs and teacher training pipelines. The long standing National Financial Education Plan (Plan de Educación Financiera) operated by the Bank of Spain (Banco de España) and the National Securities Market Commission (Comisión Nacional del Mercado de Valores, CNMV) already partners with schools and consumer bodies, so the EU strategy should integrate with this ecosystem instead of creating a parallel track. Regional consumer protection and social policies may require additional approvals or cooperation with regional consumer institutes, which can extend timelines. Fragmented authorities and differing budget cycles can delay procurement and complicate consistent deployment of EU funds across regions.

Sweden

Established national brands and content governance mean EU branding should be subtle and complementary. Influencers in financial contexts are closely scrutinised under robust advertising and consumer protection standards. Municipal autonomy in education and high teacher workload are practical constraints for adoption. Public digital content is subject to exacting data protection and accessibility standards and procurement often favours open source or interoperability friendly solutions.

Mitigating national rollout challenges through extra curricular delivery?

Given the above, extra curricular instead of curricular formats might materially lower legal and operational barriers compared with embedding content in compulsory curricula. They avoid multi year curriculum approval cycles, allow rapid piloting and iteration and can be delivered by trusted non school actors under robust neutrality safeguards. The techniques below map typical pinch points to concrete extra curricular solutions that might be more compatible with EU and national frameworks.

• Constitutional competences and curriculum bottlenecks: Use after school clubs, "project weeks," school hosted but optional workshops, adult education centres, libraries and youth centres to deliver content without formal curriculum change. Frame activities under existing extra curricular authorities of schools/municipalities and conclude light touch cooperation agreements rather than curriculum decrees.
• Neutrality and boundary with marketing: Deliver through public authorities (central banks/market regulators), consumer associations and universities as primary facilitators. Apply the voluntary code of conduct to all partners, prohibit product branding and inducements and use generic or anonymised product archetypes to avoid promotions. Pre clear materials with the competent authority (where feasible) and use standard disclaimers that no investment advice is provided.
• Procurement and State aid constraints: Channel delivery via existing framework agreements, grant schemes or micro procurements for community workshops, reducing time to contract. Prefer open calls to broad not for profit and educational providers; where industry co funding is used, pool it in neutral vehicles (e.g., foundations) to mitigate selectivity and State aid concerns. Treat in kind use of public venues as de minimis support and document it transparently.
• Data protection in monitoring: Design privacy preserving evaluation – anonymous sign in, no persistent identifiers, opt in parental consent for minors, short retention, local hosting where required and DPIAs for any digital tools. Use aggregate attendance and pre/post knowledge checks without behavioural profiling.
• Language, accessibility and regional diversity: Localise extra curricular content via municipal partners and community organisations in co official languages and accessible formats (Easy to Read, sign language, captioned video). This avoids national textbook cycles while meeting equality duties.
• Teacher bandwidth and capacity: Rely on external, accredited facilitators (from central banks, regulators, universities, consumer bodies) and provide ready to use packs and micro learning modules teachers can deploy optionally, minimising the need for formal teacher training pipelines.
• Inclusive outreach and "teachable moments": Take programmes to where people already are – workplaces, employment offices, tax or social benefit touchpoints, military/voluntary service, community centres and libraries – timed to key life events (first job, tenancy, parenthood), maximising uptake without curricular change.
• Ambassadors and public messaging: Restrict ambassador roles to awareness and sign posting in community settings; script content, prohibit endorsements and separate any appearances from regulated promotions to respect national influencer/advertising rules.
• Funding pragmatics: Align with existing extra curricular funding lines (municipal education budgets, adult learning grants, Erasmus+/ESF+ projects) and use multi site lots to ensure geographic reach without over customising national curricula.

These extra curricular channels could allow Member States to demonstrate early progress, test and evaluate approaches and build political and community support ahead of any later curricular integration, while staying within national legal constraints on neutrality, advertising, procurement and data protection.

Outlook and next steps

The EU's FLS marks a significant step towards a more resilient and inclusive financial ecosystem. Its comprehensive, multi pillar design aims to equip citizens with the knowledge and confidence to make informed decisions, participate safely in capital markets and contribute to sustainable growth, while complementing existing investor protection rules and the RIS legislative track.

From 2026, the Commission envisages the launch of ambassadors, EU level campaigns, stakeholder workshops and expert meetings. Early supervisory messaging is likely to reference these initiatives and to signal expectations that firms support national efforts. By 2027, a ministerial stock take and a repeat Eurobarometer survey will inform a more granular policy stance, alongside publication of the EU voluntary code of conduct and closer ESA coordination. At that stage, firms should anticipate literacy linked expectations being embedded in supervisory priorities and, potentially, reflected in European Semester recommendations to Member States. Negotiations on the RIS may generate additional literacy related obligations or guidance on an ongoing basis and the mid term review of the Commission's retail investment workstream in 2027 could further tighten the link between retail participation objectives and investor protection, with corresponding implications for supervisory assessments of firm conduct and customer outcomes.

Implementation of the EU-FLS will be closely monitored through Eurobarometer surveys, Eurogroup/SIU monitoring and the European Semester, with a mid term review in 2027 as part of the wider SIU strategy. In parallel, ministerial stock takes, the voluntary code of conduct, expanded ESA repositories and the ambassadors' network will reinforce delivery and transparency.

Market participants, public authorities and stakeholders should engage proactively, leverage available funding and tools and align educational initiatives with the EC/OECD INFE competence frameworks and the forthcoming European code of conduct. Early, well governed participation will mitigate conduct and litigation risk, support better consumer outcomes – especially for vulnerable groups – and position firms constructively as the EU's FLS is operationalised through 2026 – 2027 and beyond.

Footnotes

1 Relevant documents and links to the press conference available here.

2 The EU defines financial literacy "...as the knowledge and skills needed to make informed financial decisions, which includes having the ability to understand financial concepts, manage personal budgets and plan for the future. It is a combination of financial awareness, knowledge, skills, attitudes and behaviours necessary for individual financial well-being and empowerment, as detailed in a framework co-published with the OECD." Accordingly, financial literacy is not "just" aimed at individuals but all those that are capable of being categorised as "retail clients" In short, if retail clients are not sufficiently educated in what choices they may have available to them and what attributes the relevant offering may have, they may invariably end up making poorer decisions than if they had the benefit of access to financial education and were sufficiently financially literate. This is further compounded when those tasked with providing the education are financial services providers, including independent financial advisors (IFAs) that may have differing priorities and interests than those they are advising on financial instruments and/or manufacturing and/or distributing financial products.

3 Available here.

4 See standalone coverage on all SIU and RIS themes available from our SIU website and thought leadership on our EU RegCORE website.

5 comprised of the (i) European Banking Authority (EBA), (ii) European Securities and Markets Authority (ESMA) and (iii) European Insurance and Occupational Pensions Authority (EIOPA).

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