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Danske Bank A/S

Danske Bank is a Nordic bank providing banking, insurance, and wealth management services.

Lobbying Activity

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament)

16 Dec 2025 · Networking

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament, Shadow rapporteur) and Novo Nordisk A/S and

18 Sept 2025 · Roundtable on sustainability omnibus

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament) and Confederation of Danish Industry and

18 Sept 2025 · Erhvervsnetværk - Sustainability omnibus

Danske Bank urges harmonised circularity rules and improved transparency

12 Sept 2025
Topic — EU legislation aiming to promote sustainable production and circular economy models.
Message — The bank calls for a single market with coherent regulations and harmonised criteria. They recommend enhanced disclosure requirements and using public procurement to reward circular performance.12
Why — Standardised rules would help the bank accurately evaluate and compare circular performance.3
Impact — Suppliers of virgin materials lose their price advantage as environmental externalities are priced.4
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Meeting with Rasmus Nordqvist (Member of the European Parliament) and Intesa Sanpaolo and

25 Jun 2025 · Closed roundtable on financing the circular economy

Meeting with Arba Kokalari (Member of the European Parliament, Rapporteur) and Deutsche Bank AG and

30 Apr 2025 · AI in Financial Services

Meeting with Maria Luís Albuquerque (Commissioner) and

24 Mar 2025 · Dinner at the House of Danish Industry and roundtable discussion

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament) and Finance Denmark

24 Mar 2025 · Conference on Shaping the Future of European Finance

Response to Savings and Investments Union

28 Feb 2025

See the attached file.
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Meeting with Kira Marie Peter-Hansen (Member of the European Parliament)

18 Feb 2025 · Lunch on financial regulation agenda

Meeting with Henrik Dahl (Member of the European Parliament)

18 Feb 2025 · The European Financial System

Meeting with Stine Bosse (Member of the European Parliament)

17 Feb 2025 · Capital Markets Union, financial markets

Meeting with Kristoffer Storm (Member of the European Parliament)

26 Sept 2024 · Financial Services

Meeting with Erik Poulsen (Member of the European Parliament)

11 Oct 2023 · Retail Investment Strategy

Meeting with Sirpa Pietikäinen (Member of the European Parliament) and Nordea Bank Abp

11 Oct 2023 · Retail Investment Strategy

Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur) and BUSINESSEUROPE and

8 Mar 2023 · Corporate Sustainability Due Diligence

Meeting with Erik Poulsen (Member of the European Parliament, Shadow rapporteur)

8 Mar 2023 · EMIR

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

29 Sept 2022 · CRR3 / CRDVI (staff)

Meeting with Niels Fuglsang (Member of the European Parliament)

16 Sept 2022 · Finance

Meeting with Sara Skyttedal (Member of the European Parliament)

29 Apr 2022 · European Banking union

Meeting with Tommy De Temmerman (Cabinet of Commissioner Mairead Mcguinness) and Finanssiala ry - Finance Finland and

9 Dec 2021 · Basel III

Meeting with Johannes Hahn (Commissioner)

8 Jun 2021 · Keynote speech and discussion on European policy priorities and recovery.

Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

Danske Bank Sweden strongly supports the work of the Commission in the establishment of a framework to facilitate sustainable investments and in creating common standards for sustainable economic activities (the EU Taxonomy). Therefore, we much welcome the opportunity to provide input for the Commission’s final deliberations on the EU Taxonomy and its screening criteria. A across the Nordic economies, not the least in Sweden, forest management has been conducted actively and responsibly for decades. However, we observe that contrary to the recommendations of the Commission’s Technical Expert Group (TEG), the Technical Screening Criteria (TSC) of the Taxonomy now requires improvement of and “additionality” in forest management practices in order to achieve eligibility. Thus the TSC no longer takes into account the ongoing contribution to climate change mitigation, but merely incremental changes (the second order derivative). While supportive of incentivising improvements in forest management, we are concerned that the “additionality” requirements will limit the assets eligible for sustainable financing, and in turn reduce the potential supply of “green” investment products for investors. Especially our ability to issue green bonds based on such assets would become limited. This would be to the detriment of both sustainable forest management and the availability of otherwise attractive sustainable financial assets for investors. To put these criterion in context, existing forest management in Sweden helps to absorb approximately 38 million tons CO2-equivalents on an annual basis (NB: Net after annual harvesting). For comparison, the total, national greenhouse gas emissions comprise approximately 51 million tons of CO2-equivalents per annum *). Forest management thus in our view contributes substantially to climate change mitigation, and should remain eligible for sustainable financing as also recommended by the TEG. Furthermore, we observe that the TSC would appear in conflict with the inclusion of forestry as a carbon sink: In the Commission’s recently proposed changes to the 2030 EU Climate Target Plan, the carbon sink properties from land use, land use change and forestry (LULUCF) are clearly acknowledged, and will be included in national CO2 emission targets going forward. The recent changes to the Draft Taxonomy Delegated Acts thus appear less suited to achieve the overall objectives of the EU’s overall climate agenda. In addition, they would risk unduly excluding an economic activity with proven sustainable credentials from cost efficient financing. Therefore, we strongly urge the Commission to reconsider the TSC with the objective to remove the “additionality” requirements from the Taxonomy’s “Annex I forestry criteria”, and reapply the ’existing forest management’ criteria as defined by the TEG. *) Numbers for 2019 from Swedish Environmental Protection Agency (Naturvårdsverket)
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Response to Sustainable corporate governance

8 Oct 2020

Danske Bank welcomes the Commission’s inception impact assessment and supports further alignment of the sustainability requirements that apply to the European corporate governance framework. Further alignment will increase transparency and may assist to reduce regulatory fragmentation due to individual Member States introducing (further) mandatory horizontal due diligence schemes or initiatives related to corporate governance. As a starting point, we however suggest that the EU Commission maps more thoroughly the extent to which Member States’ regulations already cover specific parts of sustainability for specific types of companies. As an example, both the Danish Companies Act and the Danish Financial Business Act govern many sustainability related topics. Also, the Commission should closely monitor the impact of recently launched initiatives such as the updated Shareholders Rights Directive and the Sustainable Finance Disclosure Regulation, which we believe may also significantly impact companies’ sustainability decisions and strategies. These would thus be important factors to consider in order to ensure a comprehensive and coherent regulatory EU framework. Secondly, we observe that definitions of “sustainability” may vary significantly across Member States. As an example, when “sustainability” was included as a remuneration metric in section 139a of the Danish Companies Act, the Danish Business Authority issued guidelines specifically addressing what may be included for sustainability. As such, it was found that sustainability could be both internal and external, but it was left for the companies to determine how to implement/measure this. Uniform definitions, guidelines and standards across Member States building upon the Commission’s sustainable finance framework would therefore be important to consider. Thirdly, as investors and other stakeholders increasingly focus on sustainability, we believe that the market appetite in investing into companies with an embedded sustainable corporate governance model is increasing. In this respect, mandatory disclosures are a highly effective way of highlighting a company’s sustainability decisions and strategies to relevant investors / fiduciaries – and to probe for, as necessary, shareholder engagement. We trust that the revisions to the Non-Financial Reporting Directive will cater for current data gaps in this respect. However we would favour any supplementing guidelines/standards deemed necessary to improve company disclosures on sustainability issues. If applied in a uniform manner across EU Member States, extending the use of disclosures would in our view thus incentivise the executive management and boards of companies to further integrate wider interests into corporate decision making and incentive programs etc. Such disclosures could e.g. comprise KPIs that link to sustainability and do-no-harm elements of management remuneration or the how the tasks of ensuring sustainability and long-term orientation of the company are anchored at a Board level. Finally, we stress the need to ensure alignment of this initiative with thematically overlapping initiatives under the EU Action Plan, eg.; principal adverse impact considerations should be fully aligned with indicators that Financial Market Participants / Financial Advisers are required to report on under SFDR. Further, a potential legislative initiative should in respect to consideration and inclusion of sustainability risks in the governance model appreciate the relevant sectoral framework applicable to financial institutions with coming changes to CRR / CRD IV, AIFMD, UCITS, MiFID II etc.
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Meeting with Aliénor Margerit (Cabinet of Commissioner Paolo Gentiloni)

20 Feb 2020 · European Green Deal

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

21 Nov 2018 · EMU

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

10 Sept 2018 · Basel III

Meeting with Jonathan Hill (Commissioner)

4 Mar 2016 · Digitalization of payments; Call for evidence; CMU

Meeting with Mette Toftdal Grolleman (Cabinet of Commissioner Jonathan Hill)

14 Oct 2015 · CRR-Review; Covered Bonds Consultation; Retail Green Paper

Meeting with Astrid Cousin (Cabinet of Commissioner Margrethe Vestager)

25 Sept 2015 · Capital Markets Union, EMU and EU Banking Sector

Meeting with Mette Toftdal Grolleman (Cabinet of Commissioner Jonathan Hill)

10 Dec 2014 · Banking Structural Reform and Capital Markets Union