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Bundesverband deutscher Banken e.V.

Bankenverband

The Association of German Banks represents around 152 private banks and seven member associations in Germany.

Lobbying Activity

Meeting with Manuel Mateo Goyet (Acting Head of Unit Communications Networks, Content and Technology)

21 Jan 2026 · Upcoming CADA and its impact on the banking sector

Meeting with Markus Ferber (Member of the European Parliament)

13 Jan 2026 · Securitisation

German Bank Association demands innovation-friendly EU Quantum Act

26 Nov 2025
Topic — The initiative coordinates EU research and investment to industrialize quantum technologies.
Message — The association calls for the EU to recognize banks as key stakeholders and provide them with access to quantum hardware. They urge policymakers to create innovation-friendly regulations and regulatory sandboxes to support practical testing.123
Why — These measures would secure a competitive advantage for banks through early technological leadership.45
Impact — Non-EU tech firms could lose market dominance as Europe seeks technological sovereignty.6
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Meeting with Martin Merlin (Director Financial Stability, Financial Services and Capital Markets Union)

17 Nov 2025 · Market Infrastructure Package

Meeting with Jan Ceyssens (Cabinet of Commissioner Jessika Roswall)

6 Nov 2025 · EU Deforestation Regulation (EUDR)

Meeting with Giovanni Crosetto (Member of the European Parliament, Shadow rapporteur) and Fédération bancaire française and

5 Nov 2025 · Securitisation Framework

German Banking Industry Urges Longer Timeline for Electronic Signature Rules

2 Oct 2025
Topic — EU regulation defining formats for advanced electronic signatures and seals for public sector bodies.
Message — The organization requests a longer transition period beyond 12 months and clear compliance mechanisms for alternative validation methods. They argue the current timeline may be too short for implementation and that undefined certification procedures could create legal uncertainty.1234
Why — This would give banks more time to adapt technical systems and avoid fragmented compliance requirements.56
Impact — Citizens and businesses lose faster access to harmonized digital signature systems across EU.
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German Banking Industry Urges Browser Compatibility for EU Website Certificates

2 Oct 2025
Topic — EU regulation setting reference standards for qualified certificates for website authentication.
Message — The banking associations request adding language to ensure qualified certificates for website authentication remain compatible with global browser root store policies. They argue this alignment is necessary to avoid fragmentation and ensure certificates are both legally valid and technically functional.12
Why — This would ensure their EU-recognized certificates work seamlessly in major browsers without technical barriers.34
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German Banking Industry Urges Stronger Cross-Border Trust Standards for Digital Archiving

2 Oct 2025
Topic — EU rules for qualified electronic archiving services under the eIDAS regulation.
Message — The banking sector requests clarification on technological validity periods and designation of national authorities to monitor obsolescence. They seek explicit requirements for cross-border interoperability and legal recognition of archived documents across Member States.123
Why — This would increase legal certainty for banks managing electronic documents across borders.45
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German Banking Industry seeks clarity on electronic ledger standards

2 Oct 2025
Topic — EU regulation setting technical standards for qualified electronic ledgers and digital wallets.
Message — The banking associations request clarifying the regulation's future scope and ensuring cross-border interoperability of consensus mechanisms. They want explicit language signaling potential inclusion of other ledger models as standards evolve.12
Why — This would provide regulatory certainty and flexibility as blockchain technology evolves.34
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German banks urge clearer rules for digital identity trust services

2 Oct 2025
Topic — EU regulation on requirements for qualified trust service providers in digital identity systems.
Message — The banking associations request a threshold-based notification system and clear definitions to avoid legal uncertainty. They seek clarity on supervisory oversight of termination plans and obligations when using subcontractors.1234
Why — This would reduce compliance uncertainty and provide clearer operational boundaries for banks.56
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Meeting with Valdis Dombrovskis (Commissioner) and

24 Sept 2025 · the digital euro proposal and EU Competitiveness

Meeting with Ralf Seekatz (Member of the European Parliament, Rapporteur) and KfW Bankengruppe and True Sale International GmbH

23 Sept 2025 · Verbriefung

Meeting with Alexandra Jour-Schroeder (Deputy Director-General Financial Stability, Financial Services and Capital Markets Union) and Fédération bancaire française

19 Sept 2025 · The European Union’s competitiveness agenda and the Sav-ings and Investment Union (SIU)

Meeting with Almoro Rubin De Cervin (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

2 Sept 2025 · Meeting on simplification and competitiveness

Meeting with Eric Ducoulombier (Acting Director Financial Stability, Financial Services and Capital Markets Union)

3 Jul 2025 · Savings and Investment Union

Meeting with Nils Behrndt (Deputy Director-General Justice and Consumers)

2 Jul 2025 · Exchange of views on 28th Regime

Meeting with Dan Dionisie (Head of Unit Justice and Consumers)

2 Jul 2025 · Exchange of views on the 28th Regime

German banks advocate for private-led European investment accounts

26 Jun 2025
Topic — The EU is creating a blueprint for European savings and investment accounts.
Message — Banks want to use existing investment products rather than new state-designed ones. They propose tax exemptions, subsidies, and no mandatory pension guarantees for investors. Credit institutions should manage these accounts to offer a wide range of securities.1234
Why — Banks would secure a monopoly on managing these new tax-advantaged investment vehicles.5
Impact — Public pension systems and state-run providers lose potential roles in new savings initiatives.6
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German Banks Urge Simpler Labels in EU Green Finance Review

28 May 2025
Topic — A consultation on revising EU rules for sustainable finance disclosures and labels.
Message — The group proposes three clear product categories—Sustainable, Transition, and ESG Basic—to replace current complex rules. They recommend scrapping website disclosures and simplifying technical reports to prevent overwhelming retail investors.12
Why — This would lower administrative costs by removing burdensome reporting requirements and website updates.3
Impact — Transparency advocates lose access to detailed data if website disclosures and impact statements are removed.45
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Meeting with Elena Arveras (Cabinet of Commissioner Maria Luís Albuquerque)

15 May 2025 · Sustainable Omnibus

Response to Verification of identity and attributes at qualified certificate or qualified attestation of attributes issuance

13 May 2025

The German Banking Industry Committee (GBIC) fully supports the attached comments of the European Credit Sector Associations (European Association of Co-operative Banks, European Banking Federation, and European Savings and Retail Banking Group ECSAs) on the draft implementing regulation concerning reference standards for the verification of the identity and attributes of person to whom the qualified certificate or the qualified electronic attestation of attributes is to be issued in the context of European Digital Identity Wallets (EUDIWs).
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Response to Management of remote qualified signature creation devices as a qualified trust service

13 May 2025

The German Banking Industry Committee (GBIC) fully supports the attached comments of the European Credit Sector Associations (European Association of Co-operative Banks, European Banking Federation, and European Savings and Retail Banking Group ECSAs) on the draft implementing regulation concerning the management of remote qualified electronic signature creation devices and of remote qualified electronic seal creation devices as qualified trust services in the context of European Digital Identity Wallets (EUDIWs).
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Response to Qualified certificates for electronic signatures and electronic seals

13 May 2025

The German Banking Industry Committee (GBIC) fully supports the attached comments of the European Credit Sector Associations (European Association of Co-operative Banks, European Banking Federation, and European Savings and Retail Banking Group ECSAs) on the draft implementing regulation concerning reference standards for qualified certificates for electronic signatures and qualified certificates for electronic seals in the context of European Digital Identity Wallets (EUDIWs).
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Response to Validation of qualified electronic signatures and seals as well as advanced electronic signatures and seals

13 May 2025

The German Banking Industry Committee (GBIC) fully supports the attached comments of the European Credit Sector Associations (European Association of Co-operative Banks, European Banking Federation, and European Savings and Retail Banking Group ECSAs) on the draft implementing regulation concerning the validation of qualified electronic signatures and of qualified electronic seals and the validation of advanced electronic signatures based on qualified certificates and of advanced electronic seals based on qualified certificates in the context of European Digital Identity Wallets (EUDIWs).
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Response to Qualified validation services for qualified electronic signatures and seals

13 May 2025

The German Banking Industry Committee (GBIC) fully supports the attached comments of the European Credit Sector Associations (European Association of Co-operative Banks, European Banking Federation, and European Savings and Retail Banking Group ECSAs) on the draft implementing regulation concerning qualified validation services for qualified electronic signatures and qualified validation services for qualified electronic seals in the context of European Digital Identity Wallets (EUDIWs).
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Response to Notification and verification of the initiation of a qualified trust service

13 May 2025

The German Banking Industry Committee (GBIC) fully supports the attached comments of the European Credit Sector Associations (European Association of Co-operative Banks, European Banking Federation, and European Savings and Retail Banking Group ECSAs) on the draft implementing regulation concerning the format and procedures for notification of intention and verification with regard to the initiation of qualified trust services in the context of European Digital Identity Wallets (EUDIWs).
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Response to Provision of qualified electronic time stamping services

13 May 2025

The German Banking Industry Committee (GBIC) fully supports the attached comments of the European Credit Sector Associations (European Association of Co-operative Banks, European Banking Federation, and European Savings and Retail Banking Group ECSAs) on the draft implementing regulation concerning the binding of date and time to data and establishing the accuracy of the time sources for the provision of qualified electronic time stamps in the context of European Digital Identity Wallets (EUDIWs).
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German banking industry urges fair standards for digital identity reviews

13 May 2025
Topic — The consultation concerns procedural rules for peer-reviewing national electronic identification schemes within the EU.
Message — The association demands a level playing field to prevent regulatory arbitrage across Member States. Any refusal of peer reviewers must be based on clear evidence rather than discretion. Member States should justify withholding information during reviews to ensure transparency.123
Why — Consistent rules prevent competitors from seeking jurisdictions with weaker oversight to gain advantage.4
Impact — Member States might lose the power to shield domestic schemes from rigorous cross-border scrutiny.5
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Response to Submissions of the annual reports by supervisory bodies to the Commission

13 May 2025

The German Banking Industry Committee (GBIC) fully supports the attached comments of the European Credit Sector Associations (European Association of Co-operative Banks, European Banking Federation, and European Savings and Retail Banking Group ECSAs) on the draft implementing regulation concerning the formats and procedures for annual reports by supervisory bodies in the context of European Digital Identity Wallets (EUDIWs).
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Meeting with Arba Kokalari (Member of the European Parliament, Rapporteur) and Deutsche Bank AG and

30 Apr 2025 · AI in Financial Services

Response to Technical description of important and critical products with digital elements

11 Apr 2025

Please find our feedback in the file attached. Kind regards Bundesverband deutscher Banken e.V. Association of German banks Berlin, Germany
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Response to 2025 Strategic Foresight Report

19 Mar 2025

The Bankenverband (Association of German Banks) represents private banks And fintechs in Germany and advocates for a stable and competitive European financial sector. We welcome the consultation on Strategic Foresight 2025 and appreciate the European Commissions ongoing efforts in this area. The importance of Strategic Foresight is crucial in shaping a resilient and forward-looking financial and economic framework. The Bankenverband has developed a feedback and its own Strategic Foresight Report, which can be found in the attached file.
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Response to Savings and Investments Union

7 Mar 2025

Summary Association of German Banks Call for Evidence on the Savings and Investment Union Deep and efficient EU financial markets are vital for the financing of the EUs upcoming challenges: innovation, transformation, demographic changes, security and resilience. The key element in achieving this will be a regulatory framework that makes the capital markets not only secure and efficient, but also attractive and liquid, i.e. globally competitive. It is imperative for the further development of the EU capital market that competitiveness is used as a guiding principle for revising existing EU rules and for drafting new regulations. There are regulatory as well as non-regulatory measures that need to be taken. We would like to highlight the following: o Securitisations: A change of the excessive state of the regulations is necessary, especially the capital requirements for securitisation positions pursuant to the CRR, and due diligence and transparency requirements for securitisation transactions (see attachment). o Attracting retail investors and channelling citizens funds into long-term capital market investments: RIS / pensions: We emphasize that the use of investment accounts should be incentivised and made attractive. Investment savings should be easy for the public to comprehend, free of unnecessary administrative hurdles, and thus simple to implement. At the same time, there is no need for state-designed products whereas the market should continue to identify and design products based on the needs and requirements of retail investors (see attachment). o VAT: EU-wide standardised and legally certain VAT regulations in the financial services sector are an important component of the SIU (see attachment). o Global minimum taxation: Simplifications to global minimum taxation (Pillar 2) are essential to avoid unnecessary burdens for financial institutions and to maintain competitiveness (see attachment). o Strengthening the EU clearing market: Next to a pragmatic implementation of EMIR 3.0 without complex and bureaucratic reporting obligations for active accounts, a targeted harmonization of insolvency law should take place in reviewing long standing pieces of EU law: The Settlement Finality Directive (SFD) and the Financial Collateral Directive (FCD) have proven to be indispensable components of the EU capital markets architecture. They need to be adapted and modernised (see attachment). o Harmonized supervision: Europeanisation, harmonisation and coherence should only be sought where this makes sense for the development of the capital markets and ultimately for the financing of the economy.
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Meeting with Andrea Beltramello (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

28 Feb 2025 · Discussion about increasing retail investors' participation in capital markets and the need to strengthen the capital markets culture in the EU and create more trust. Investments and savings plans that exist in Germany.

Meeting with Maria Luís Albuquerque (Commissioner) and

19 Feb 2025 · Meeting with CEOs of the German Banking Industry Committee on competitiveness

Meeting with René Repasi (Member of the European Parliament) and Deutscher Sparkassen-und Giroverband and

19 Feb 2025 · Austausch zu aktuellen Fragen der europäischen Finanzmarktpolitik

Meeting with Aurore Lalucq (Member of the European Parliament, Committee chair) and Deutscher Sparkassen-und Giroverband and

19 Feb 2025 · Commission Work Programme and coming legislative proposals

Meeting with Regina Doherty (Member of the European Parliament, Shadow rapporteur)

17 Feb 2025 · FIDA

Meeting with Almoro Rubin De Cervin (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

17 Feb 2025 · FISMA D1 meeting with BdB on securitisation

Meeting with Didier Millerot (Head of Unit Financial Stability, Financial Services and Capital Markets Union) and Deutscher Sparkassen-und Giroverband and

16 Jan 2025 · Upcoming topics in sustainable finance

Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

11 Nov 2024 · Conference: exchange on the current challenges and upcoming priorities, CMU competitiveness

Meeting with Ralf Seekatz (Member of the European Parliament)

17 Oct 2024 · Allgemeiner Austausch

Meeting with René Repasi (Member of the European Parliament) and Deutscher Sparkassen-und Giroverband and

16 Oct 2024 · Working breakfast with German banking industry committee

Meeting with Jonás Fernández (Member of the European Parliament)

26 Sept 2024 · Banking Union - Capital Markets Union

Meeting with Andreas Schwab (Member of the European Parliament)

9 Sept 2024 · Priorities for the new legislative mandate

Meeting with Markus Ferber (Member of the European Parliament)

24 Jul 2024 · Legislative Agenda for the Banking Sector

Meeting with Axel Voss (Member of the European Parliament) and Zentraler Immobilien Ausschuss and Vonovia SE

23 Jul 2024 · Digital files

Meeting with Henrike Hahn (Member of the European Parliament, Shadow rapporteur) and Verband der Automobilindustrie and

21 Mar 2024 · Critical Raw Materials

Meeting with Michiel Hoogeveen (Member of the European Parliament, Shadow rapporteur)

26 Feb 2024 · Digital euro

Meeting with Michael Hager (Cabinet of Executive Vice-President Valdis Dombrovskis)

28 Nov 2023 · Exchange of views on EU banking and finance policy, including the Capital Markets Union.

Meeting with Daniel Caspary (Member of the European Parliament)

15 Nov 2023 · Teilnahme EU Public Affairs Committee

Meeting with Stefan Berger (Member of the European Parliament, Rapporteur)

15 Nov 2023 · Digital Euro

Meeting with Henrike Hahn (Member of the European Parliament, Shadow rapporteur)

8 Nov 2023 · Digital euro

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness)

3 Oct 2023 · Capital Markets Union

Meeting with Stefan Berger (Member of the European Parliament, Rapporteur)

19 Sept 2023 · Digital Euro

Meeting with Joachim Schuster (Member of the European Parliament)

23 May 2023 · Banking Regulation

Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union) and Deutscher Sparkassen-und Giroverband and

21 Mar 2023 · CMDI, Digital Euro

Meeting with Rasmus Andresen (Member of the European Parliament)

9 Mar 2023 · Sustainable Finance

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis) and Banco Santander, S.A. and

1 Feb 2023 · retail investment strategy

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis) and Deutscher Sparkassen-und Giroverband and

18 Jan 2023 · Retail investment strategy. ETFs.

Meeting with Agnieszka Drzewoska (Cabinet of Commissioner Mairead Mcguinness) and Deutscher Sparkassen-und Giroverband and

18 Jan 2023 · Retail Investment Strategy

Meeting with Tommy De Temmerman (Cabinet of Commissioner Mairead Mcguinness)

11 Jan 2023 · introductory meeting

Meeting with Tommy De Temmerman (Cabinet of Commissioner Mairead Mcguinness)

10 Jan 2023 · Bank macroprudential regulation

Meeting with Michael Hager (Cabinet of Executive Vice-President Valdis Dombrovskis)

10 Jan 2023 · Retail Investment legislative package

Meeting with Valeria Miceli (Cabinet of President Ursula von der Leyen)

16 Nov 2022 · The Association of German Banks explained their position and concerns in relation to: 1) Basel package under negotiation 2) their support to CMU initiatives 3) CMDI 4) Digital Euro

Meeting with Pim Lescrauwaet (Cabinet of Executive Vice-President Valdis Dombrovskis)

15 Nov 2022 · Economic Governance Review, Recovery and Resilience Facility, macroeconomic policy, energy policy

Meeting with Agnieszka Skonieczna (Cabinet of Commissioner Thierry Breton), Florian Denis (Cabinet of Commissioner Mairead Mcguinness)

8 Nov 2022 · Digital Euro

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis)

8 Nov 2022 · Digital euro

Meeting with Katherine Power (Cabinet of Commissioner Mairead Mcguinness)

8 Nov 2022 · Sustainable Finance

Meeting with Alin Mituța (Member of the European Parliament, Shadow rapporteur) and Alibaba and European Materials Handling Federation

11 Jul 2022 · Data Act

Meeting with Esther De Lange (Member of the European Parliament)

29 Jun 2022 · Banking Package - APA

Meeting with René Repasi (Member of the European Parliament)

23 Jun 2022 · Kennenlernen

Meeting with Joachim Schuster (Member of the European Parliament) and Deutsche Bank AG and

21 Jun 2022 · Banking package

German banks urge uniform EU consumer rules to stop gold-plating

13 Jun 2022
Topic — This consultation assesses if current EU consumer laws effectively protect digital market users.
Message — The association demands full harmonisation to prevent member states from applying diverging national requirements. They propose a tiered information system to reduce overload and maintain the principle of the responsible consumer. They also argue that young digital firms must follow the same rules as established banks.123
Why — Banks could offer identical products across the EU without adapting to local regulations.4
Impact — Emerging digital startups would face increased costs by losing their lighter regulatory status.5
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Meeting with Dārta Tentere (Cabinet of Commissioner Mairead Mcguinness)

3 Jun 2022 · Sustainable finance, taxonomy

Meeting with Roberto Viola (Director-General Communications Networks, Content and Technology)

3 May 2022 · Exchange of views on digital topics

Meeting with Tommy De Temmerman (Cabinet of Commissioner Mairead Mcguinness)

30 Mar 2022 · Banking Union

Meeting with Gilles Boyer (Member of the European Parliament, Shadow rapporteur)

15 Mar 2022 · CRR

Meeting with Mairead McGuinness (Commissioner) and

28 Jan 2022 · Basel III, macroprudential policy, Banking Union.

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness)

21 Jan 2022 · data economy, open finance

Meeting with Ralf Seekatz (Member of the European Parliament, Shadow rapporteur)

9 Nov 2021 · Geldwäschebekämpfung

Meeting with Axel Voss (Member of the European Parliament)

6 Oct 2021 · Artificial Intelligence

Meeting with Antoine Colombani (Cabinet of Executive Vice-President Frans Timmermans)

29 Sept 2021 · Sustainable Finance, Basel III

Response to EU Standard for Green Bond

27 Sept 2021

The Association of German Banks very much welcomes the opportunity to comment on the draft EU Green Bond Standard (EuGBS). In principle, we very much appriciate COM’s proposal. From our point of view, several amendments to the EuGBS are necessary in order to make EuGBS a widely used premium standard. At this point, we only highlight some key aspects and outline our further comments in an accompanying document. 1. Grandfathering We are concerned about Art. 7(1) subpara. 2 and Art. 7(2) subpara. 3 as they could imply that grandfathering of EU Green Bonds (EuGBs) would be eroded indirectly. The requirement to reallocate bond proceeds following new technical screening criteria (TSC) within five years will have a negative impact on issuers, the price of European green bonds, as well as investors. In other words: projects that were suitable for allocation before the amendment would have to be refinanced, the issuer would have to find new ”green” uses of proceeds or, in the worst case, bond proceeds would have to be repaid. This would cause serious difficulties for long-term financing. In order to provide legal certainty to issuers and investors and prevent any negative impact on the price of EuGBs already issued, it should be made clear that issuers may allocate bond proceeds under the delegated act applicable at the point in time the bond is issued, and they do not need to be replaced until their maturity. Potentially, the complexity described above might cause reluctance to issue EuGBs with a term exceeding five years . As a result, the EuGBs could be perceived as less flexible and less attractive. 2. Use of Proceeds Generally, the requirement to allocate the green bond proceeds in line with Regulation (EU) 2020/852 and the delegated acts (yet to be) adopted thereunder appears useful to ensure consistency with the EU sustainable finance taxonomy. However, it seems questionable whether 100% taxonomy conformity is possible right from the start. We are of the view that a transitional period for the use of proceeds, during which there is no requirement to allocate 100% of proceeds to EU taxonomy-aligned assets, would represent a practical and helpful phase-in for issuers. The resulting flexibility would in particular reduce risks in the context of validating compliance for those assets where experience with minimum safeguards or DNSH criteria is still low at best. A 100% requirement with no transitional period is equivalent to overly careful issuers who will prefer to use other well-known standards when issuing a bond and where the minimum issue size appears more easily achievable. This holds true especially for smaller banks. A threshold of 80% and a five-year transitional period would be reasonable. 3. Costs of the issuance It appears unusual that the costs of the issuance of a green bond cannot be settled out of the proceeds of the issuance. The issuance process always generates costs (such as fees for underwriting, prospectus approval, listing, the external reviewer, legal advisors, auditors, or cost for the printing of a prospectus). These costs are normally allocated to the individual bond issuance. However, the ICMA Green Bond Principles only provide for the use of the “net proceeds” of the issuance (after deduction of costs). Such a prohibition would result in unnecessary complexity as other sources of financing will have to be sought and, hence, reduce the attractiveness of EuGBs. Moreover, it would also have accounting implications and could raise further questions, for example whether such costs are an eligible expense for determining the tax liability of the issuer. 4. Art. 2(3)(f) Definitions The definition of a “sovereign” is quite far-reaching. It also includes private companies that are state owned but are competing with pure-play private companies. It results in an unfair competitive advantage as opposed to their privately owned competitors. This should be reconsidered.
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Meeting with Mairead McGuinness (Commissioner)

7 Sept 2021 · Pre-record for Awards Ceremony.

Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

2 Sept 2021 · Basel III

Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

5 Jul 2021 · Basel III reform

Meeting with Michael Hager (Cabinet of Executive Vice-President Valdis Dombrovskis) and Fédération bancaire française and

28 Jun 2021 · Basel III

Meeting with Katherine Power (Cabinet of Commissioner Mairead Mcguinness)

5 May 2021 · Sustainable Finance

Meeting with Valeria Miceli (Cabinet of President Ursula von der Leyen) and Fédération bancaire française

28 Apr 2021 · Implementation of Basel 3

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness), Tommy De Temmerman (Cabinet of Commissioner Mairead Mcguinness)

28 Apr 2021 · Open Strategic Autonomy

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis) and Deutscher Sparkassen-und Giroverband and

7 Apr 2021 · Basel III

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis), Michael Hager (Cabinet of Executive Vice-President Valdis Dombrovskis)

31 Mar 2021 · Financial services policy

Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union) and Deutsche Bank AG and Fédération bancaire française

17 Feb 2021 · Basel III

Meeting with Mairead McGuinness (Commissioner)

2 Feb 2021 · Introductory Meeting Priorities in the field of banking and financial market regulation.

Meeting with Valeria Miceli (Cabinet of President Ursula von der Leyen)

22 Jan 2021 · Advancing a single European banking market

Meeting with Tommy De Temmerman (Cabinet of Commissioner Mairead Mcguinness)

21 Jan 2021 · Basel III

Meeting with Agnieszka Drzewoska (Cabinet of Commissioner Mairead Mcguinness), Florian Denis (Cabinet of Commissioner Mairead Mcguinness)

21 Jan 2021 · Retail Finance, Digital Finance, CMU

Response to EU single access point for financial and non-financial information publicly disclosed by companies

15 Jan 2021

We firmly support this proposal to improve access to data relevant for investment decisions by building a European Single Access Point (ESAP). We agree with the European Commission’s considerations that investors in capital markets must have access to information about companies and financial products in order to make sound investment decisions. We further agree that investor confidence and willingness to invest in capital markets, in particular by retail investors, would be fostered by easy availability, quality and comparability of this information. Such data base will need to be simple, reliable, and user friendly. Data quality via standardised information will be key to make this data base a success.
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Meeting with Katherine Power (Cabinet of Commissioner Mairead Mcguinness), Tommy De Temmerman (Cabinet of Commissioner Mairead Mcguinness)

13 Jan 2021 · Banking Union, AML, Sustainable Finance

Response to Directive/regulation establishing a European framework for markets in crypto assets

11 Jan 2021

Second try, since upload of the PDF document seems to not have worked out: The Association of German Banks welcomes the European Commission’s intention to run pilot operations to identify what adjustments need to be made to existing EU regulation of services involving the issuance, safekeeping and asset servicing, trading and settlement of DLT financial instruments and, in parallel, to develop practicable proposals for a suitable regulatory framework and targeted adjustments to selected EU legislation. We would therefore like to share our current analysis of the proposed regulation and our considerations and suggestions on how to optimise the envisaged pilot operations in order to gain broad experience and promote the full potential of DLT applications in capital markets. Please see our comments in the attached PDF.
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Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis)

30 Nov 2020 · Sustainable finance

Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

12 Nov 2020 · Key topics for the banking sector and the economic recovery

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis)

15 Sept 2020 · Digital finance

Response to EU Standard for Green Bond

7 Aug 2020

The Association of German Banks very welcomes the opportunity to comment on the European Commission’s Inception impact assessment on EU Green Bond Standards (EU GBS). Green bonds may prove instrumental in mobilizing the bond market for climate change solutions. The Green Bond market has considerably raised its volumes and is expected to grow further. Additionally, we also note the emergence of Social and Sustainable Bonds, catalyzed by International Capital Market Association (ICMA). We would like to encourage the European Commission to follow the recommendations of the Technical Expert Group to support the further development of green bonds. A common framework could ensure minimum standards and foster the credibility and integrity of the European green bond market. However, the goal should be not to overregulate and to still allow for enough flexibility and different methodologies in market-driven initiatives. Generally, it should be noted that products which are issued under currently established Green Bond Standards (GBS, e.g. ICMA Green Bond Principles) should not lose their status as "green" due to the introduction of EU GBS ("grandfathering"). The grandfathering of products issued under previously established GBS is very important for both issuers and investors, as this has implications for legal certainty, confidence in the market and finally the ability to trade these products. This applies likewise to products issued under the future EU GBS, as these standards will also be subject to ongoing development. Not all market participants may be able to comply with the EU GBS. Therefore, in order to allow for a smooth transition towards the new standard and not to limit issuance activity in the green bond market, we suggest introducing the EU GBS as a label. It should still be possible for EU issuers/arrangers to offer a green bond in line with other market standards (e.g. the ICMA Principles). A strictly binding EU GBS for every green bond issued in the EU should be excluded, as this would hurt the market for issuers from other continents who want to tap into the European capital markets. The market needs a coexistence of both EU GBS and other established GBS (e.g. the ICMA Principles). The EU GBS may however be promoted by encouraging issuers and investors to comply with the new EU GBS, by linking any incentives to compliance with the new standard. In order to promote the integrity (i.e. preventing “greenwashing“), harmonization and efficiency of the green bond market, as well as to increase investor confidence, it is essential for issuers to obtain a standardized external verification of green bonds against the EU GBS. In order to ensure sufficient qualification and quality we endorse the definition of minimum standards and accreditation of External Verifiers. In terms of content of the External Verification we note that Second Party Opinions have become market standard in the European green bond market and therefore may become a mandatory requirement under the EU GBS. Also, alternative ways of external post-issuance review, e.g. annual review of an issuer’s compliance with his Green Bond Framework by the Verifier providing the Second Party Opinion, may be considered. To help the growth of green and sustainability-linked bonds, the higher cost for issuers due to additional transparency requirements should be alleviated. A possible subsidy, to offset the additional cost of external verification/second opinion, or targeted fiscal incentives, are likely to increase the attractiveness of green bonds as they offset the issuance costs with conventional bonds. As a first step an incentive to cover the external costs for the Second Party Opinion for green bonds compliant with the EU GBS would be an instrument which can be easily and efficiently implemented and which would help to promote the new EU GBS. In addition to incentives for the issuer, EU member states should also consider tax incentives for the investor.
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Response to Action Plan on the Capital Markets Union

4 Aug 2020

The Association of German Banks has strongly backed the capital markets union project from the outset (COM Action Plan 2015). As a supporter of the Markets for Europe campaign (2019 Roadmap), we call on the new/current Commission to drive the project forward with ambition. We warmly welcome the recently published report of the High Level Forum on CMU. We believe it identifies many important steps that need to be taken to achieve real capital markets union. We share the view that an efficient, pan-European capital market is essential to financing the post-covid-19 recovery and the modernisation of the European economy and to ensuring Europe’s long-term competitiveness and sovereignty. The UK’s recent announcement on 23 June 2020 that it intends to go its own way in key areas of financial regulation makes rapid progress in building EU capital markets union more urgent than ever. We therefore attach i) our comments evaluating a number of the measures proposed by the High Level Forum in its consultation, and ii) our position paper of 19 February 2020, in which we recommend eight concrete measures to deepen capital markets union that could be implemented in the current legislative term. We also welcome the proposals presented by the Commission on 27 July 2020 in its Covid-19 Recovery Package as the first concrete steps towards deepening capital markets union. We welcome the amendments proposed for the Benchmarks Regulation, MiFID II and securitisations. Amendments to the Prospectus Regulation rightly address a considerable problem but, in our opinion, require further review in the course of the legislative process to ensure there can be no doubt about legal certainty. We also consider it necessary that the planned review of the CSDR remove any uncertainties surrounding the current settlement discipline regime. We welcome the European Commission’s initiative to promote the securitisation market by easing NPL securitisation and the on-balance sheet securitisation of SME loans. The current unequal treatment of NPL securitisations should be remedied, giving Europe’s banks more scope to remove non-performing loans from their balance sheets. Furthermore, treating senior tranches of STS on-balance sheet securitisations like traditional STS securitisations, as suggested by the Commission, eases amongst other things the securitisation of SME loans, which promotes investment and creates jobs and growth.
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Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

25 May 2020 · Covid-19 Banking package and CRR Quick fix

Meeting with Michele Piergiovanni (Cabinet of Executive Vice-President Margrethe Vestager)

8 Apr 2020 · To discuss the upcoming review of the Interchange Fee Regulation (IFR)

Response to Action Plan on anti-money laundering

10 Mar 2020

Dear Sir or Madame, Please find attached the position of the Association of German Banks on AML & CTF Regulation in the EU. Sincerely yours, Tobias Frey
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Meeting with Jérome Deslandes (Cabinet of Executive Vice-President Valdis Dombrovskis)

18 Feb 2020 · Presentation of German Banks’ position on Basel III

Meeting with Michael Hager (Cabinet of Executive Vice-President Valdis Dombrovskis)

6 Feb 2020 · Banking Union, Capital Markets Union

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis)

6 Feb 2020 · DIGITAL FINANCE

Meeting with Michael Hager (Cabinet of Executive Vice-President Valdis Dombrovskis)

6 Feb 2020 · Capital requirements, FINTECH

Meeting with Günther Oettinger (Commissioner)

25 Sept 2019 · MFF

Meeting with Jan Ceyssens (Cabinet of Vice-President Valdis Dombrovskis)

6 Feb 2019 · International Role of the Euro

Response to Public consultation on minimum requirements in the transmission of information for the exercise of shareholders rights

8 May 2018

Please find enclosed the Comments of the Bundesverband deutscher Banken (Association of German Banks). It represents more than 200 private commercial banks in Germany.
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Meeting with Paulina Dejmek Hack (Cabinet of President Jean-Claude Juncker) and Konrad-Adenauer-Stiftung

23 Apr 2018 · Panel discussion at the conference "A future is now - A changing banking sector"

Response to Fitness check on public reporting by companies

6 Mar 2018

Sehr geehrte Damen und Herren, vielen Dank für die Möglichkeit, Anmerkungen zum Fahrplan der Initiative abgeben zu können. Kürzlich hat die ESMA den Draft RTS on the European Single Electronic Format (ESEF) an die EU-Kommission zur Genehmigung übermittelt. Auch wenn die Abbildung von Bankbilanzen im ESEF technisch machbar ist, sehen wir keinerlei Mehrwert in der Anwendung dieses Formats. Die IFRS-Taxonomie ist für eine adäquate Abbildung bankspezifischer Sachverhalte ungeeignet. Folglich werden Analysten nach wie vor auf die Pdf-Dokumente des Finanzberichts zurückgreifen. Mit der Anforderung, die Abschlussdaten in das ESEF zu übertragen, wird unnötiger Aufwand generiert, der zudem den Better-Regulation-Prinzipien der EU-Kommission und dem Gebot des Bürokratiekostenabbaus widerspricht. Mit freundlichen Grüßen
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Meeting with Jean-Claude Juncker (President) and

10 Jan 2018 · Meeting with Mr Hans-Walter Peters on Banking Union and Deepening of Economic and Monetary Union

Meeting with Reinhard Felke (Cabinet of Commissioner Pierre Moscovici)

10 Jan 2018 · Exchange of views on the future of EMU

Response to Fairness in platform-to-business relations

22 Nov 2017

With reference to the European Commission’s preliminary assessment on fairness in platform-to-business relations we suggest to address the following business practices which have an impact on the competition between platform providers and business users. Unbundling marketplace and payment services Nowadays, small online retailers often do not sell their products on proprietary shops, but via online marketplaces. The market for such platforms is however highly concentrated in most European countries. Large providers often prescribe main platform functionalities to retailers, including a pre-selection of available payment methods that are part of a larger service offering (‘product bundle’/ ‘tied offering’). This practice represents an abuse of dominant market positions and distorts the competition for online payment service providers by cutting out major parts of the addressable market. A notable legal precedent for the restriction of tying is the opening of the web browser market when the Commission made commitments of Microsoft legally binding under article 102 of the TFEU (cf. IP/09/1941). Suggestion: Unbundling of online marketplace and payment services: Providers of online marketplaces with a market-dominating position shall commit to grant free choice of payment methods and payment service providers to retailers on their platforms. Access to essential infrastructures (e.g. for M-Payments) Manufacturers of mobile devices (e.g. smartphones, tablets, wearables) own patents for components of their products that are required for mobile payments. Some of these manufacturers use this control to promote their proprietary payment solutions (e.g. apps), thereby hindering third party providers to access device components and/ or use patents to offer further payment solutions. Given the highly concentrated mobile device market, this practice distorts the competition for M-Payments. Suggestions: Any components of a mobile device that can be used for data entry, transmission, authorization and data storage in payment processes shall be considered as essential infrastructure for mobile payments methods. Payment service providers shall get access to essential infrastructure from mobile device manufacturers at fair, reasonable and non-discriminatory (licensing) conditions. Manufacturers of mobile devices with market-dominant position shall commit to grant access to essential infrastructures (as defined in the PSD) to payment service providers at fair, reasonable and non-discriminatory (licensing) conditions.
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Meeting with Olivier Guersent (Director-General Financial Stability, Financial Services and Capital Markets Union)

22 Nov 2017 · Basel

Meeting with Lora Borissova (Cabinet of Commissioner Mariya Gabriel)

22 Nov 2017 · digital payments

Meeting with Jan Ceyssens (Cabinet of Vice-President Valdis Dombrovskis)

19 Oct 2017 · CMU

Meeting with Jyrki Katainen (Vice-President)

19 Oct 2017 · Financial Services and EMU

Meeting with Jan Ceyssens (Cabinet of Vice-President Valdis Dombrovskis), Kai Wynands (Cabinet of Vice-President Valdis Dombrovskis) and

5 Sept 2017 · Banking Union; ESA review; CRR/CRD; PSD2

Meeting with Elina Melngaile (Cabinet of Vice-President Valdis Dombrovskis)

30 Aug 2017 · PSD2

Meeting with Martin Selmayr (Cabinet of President Jean-Claude Juncker)

29 Aug 2017 · The European Union : Towards a Challenging Year

Response to Review of Regulation on cross-border payments

25 Jul 2017

The Association of German Banks (BdB) represents the interests of approximately 200 private banks. We see no need for any action to extend the scope of Regulation (EC) 924/2009 to cover all currencies or other EU currencies. Generally speaking, we do not consider charges/fees for cross-border payments in EU currencies (or other currencies) other than the euro to be excessive. European lawmakers should not interfere in how the market sets fees (providers should be free to establish fees via bilateral or multilateral agreements). Charges for cross-border payments in an EU currency other than the national currency or in the currency of a non-EU country are higher for a reason. Such payments require the PSP in question to buy or sell the currency on the relevant currency market. This entails higher costs than for euro-denominated national and cross-border payments within the EU. It is therefore only logical that fees for cross-border and national payments in currencies other than the euro will not be identical. A far better approach, in our view, would be to explore non-legislative options such as encouraging market initiatives that bring more transparency to the cost of cross-border transactions.
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Meeting with Ruth Paserman (Cabinet of Commissioner Marianne Thyssen) and Institut der deutschen Wirtschaft Köln e.V.

28 Jun 2017 · “Future of the European Monetary Union – how to deepen the Eurozone?”

Meeting with Paulina Dejmek Hack (Cabinet of President Jean-Claude Juncker)

28 Jun 2017 · Financial services agenda

Meeting with Reinhard Felke (Cabinet of Commissioner Pierre Moscovici)

15 May 2017 · Exchange of views on the economic prospect for the Euro Area

Meeting with Kai Wynands (Cabinet of Vice-President Valdis Dombrovskis)

10 May 2017 · Risk reduction package and Basel (general aspects), PSD2

Meeting with Lee Foulger (Cabinet of Vice-President Valdis Dombrovskis)

20 Oct 2016 · Securitisation

Meeting with Mette Toftdal Grolleman (Cabinet of Vice-President Valdis Dombrovskis)

8 Sept 2016 · CRR and CRD IV

Meeting with Valdis Dombrovskis (Vice-President) and

22 Jun 2016 · Completing EMU in particular EDIS

Meeting with Günther Oettinger (Commissioner)

22 Jun 2016 · DSM

Meeting with Andreas Schwarz (Cabinet of Vice-President Kristalina Georgieva) and Bundesverband der Deutschen Industrie e.V. and

16 Jun 2016 · MFF Mid-term review

Meeting with Markus Schulte (Digital Economy)

6 Apr 2016 · Digitisation

Meeting with Martin Selmayr (Cabinet of President Jean-Claude Juncker)

4 Dec 2015 · Completion of Banking Union

Meeting with Günther Oettinger (Commissioner)

3 Dec 2015 · DSM

Meeting with Pierre Moscovici (Commissioner) and

3 Dec 2015 · exchange of views on prospects of EMU and the impact of the refugee crises

Meeting with Paulina Dejmek Hack (Cabinet of President Jean-Claude Juncker)

13 Nov 2015 · EDIS

Meeting with Markus Schulte (Digital Economy)

13 Nov 2015 · Digitisation in Banking

Meeting with Maximilian Strotmann (Cabinet of Vice-President Andrus Ansip)

21 Oct 2015 · Digitalisation, public eServices, interoperability

Meeting with Lee Foulger (Cabinet of Vice-President Valdis Dombrovskis)

7 Sept 2015 · Securitisation/Prospectus Directive

Meeting with Michael Hager (Digital Economy)

15 Jul 2015 · DSM

Meeting with Michael Hager (Digital Economy)

25 Jun 2015 · DSM

Meeting with Reinhard Felke (Cabinet of Commissioner Pierre Moscovici)

6 May 2015 · Discussion of Commission Spring Forecast and economic outlook for the euro area

Meeting with Markus Schulte (Digital Economy)

29 Apr 2015 · DSM

Meeting with Paulina Dejmek Hack (Cabinet of President Jean-Claude Juncker)

21 Apr 2015 · EFSI

Meeting with Jonathan Hill (Commissioner)

17 Mar 2015 · Financial regulation

Meeting with Sebastian Kuck (Cabinet of Commissioner Jonathan Hill)

4 Mar 2015 · Accounting

Meeting with Jan Ceyssens (Cabinet of Vice-President Valdis Dombrovskis)

2 Mar 2015 · Banking markets developments

Meeting with Valérie Herzberg (Cabinet of Vice-President Jyrki Katainen) and Bundesverband der Deutschen Industrie e.V. and Deutsche Industrie- und Handelskammer

28 Jan 2015 · Capital Markets Union

Meeting with Jan Ceyssens (Cabinet of Vice-President Valdis Dombrovskis), Massimo Suardi (Cabinet of Vice-President Valdis Dombrovskis)

3 Dec 2014 · Finanztransaktionssteuer

Meeting with Juho Romakkaniemi (Cabinet of Vice-President Jyrki Katainen), Valérie Herzberg (Cabinet of Vice-President Jyrki Katainen)

3 Dec 2014 · Investment Initiative and Capital Markets Union

Meeting with Chantal Hughes (Cabinet of Commissioner Jonathan Hill)

1 Dec 2014 · Structural reform of banks