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Deutsche Kreditbank Aktiengesellschaft

DKB AG

Gegründet wurde die DKB 1990 in Berlin.

Lobbying Activity

Response to EU taxonomy - Review of the environmental delegated act

5 Dec 2025

The DKB welcomes the call for evidence to revise Delegated Regulations (EU) 2021/2139 and (EU) 2023/2486. The DNSH and TSC require further clarification. This must operationalise the EU Taxonomy's environmental and climate objectives instead of watering them down. In particular, criteria that cross-references other applicable EU legislation should be streamlined such that financial institutions are only obliged to request data should there be indication of non-compliance. From our perspective as financiers of sustainable undertakings, it is reasonable to discard the need for requesting burdensome documentation from borrowers. Especially considering requirements intended to demonstrate that borrowers comply with rules and regulations already in place, and are presumably enforced and upheld by the dedicated institutions such as the national competent authorities. This applies particularly to criteria in sections 4.1, 4.8, 5.1, 5.3, 6.14, 6.15, 7.1, 7.2, and 7.3.
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Meeting with Rasmus Andresen (Member of the European Parliament) and Deutsche Bank AG and

9 Apr 2025 · SIU

Meeting with Gabriele Bischoff (Member of the European Parliament)

28 Mar 2025 · Austausch

Response to Taxonomy Delegated Acts – amendments to make reporting simpler and more cost-effective for companies

26 Mar 2025

Deutsche Kreditbank AG (DKB) supports the Commission's objective of simplifying the Taxonomy Delegated acts and calls for the targeted elimination of existing inconsistencies, redundancies and weaknesses. Streamlining should lead to the preservation and enhancement of the most meaningful and practically relevant points. DKB's main recommendations: +++ a) Simplification of the taxonomy conformity criteria o Targeted reduction of the Do No Significant Harm criteria (DNSH) and an in-depth analysis of the appropriateness of the criteria should be conducted o Non-substantive criteria for certain economic activities should be removed o Simplification of the minimum safeguards, especially for residential property loans and energy-efficient renovations o Deletion of the minimum safeguards for private customers and municipalities as counterparties; self-declaration is sufficient for all other counterparties b) Revision of Art. 8 of the Taxonomy Regulation o Introduction of a standardised taxonomy ratio analogous to the Banking Book Taxonomy Alignment Ratio (BTAR) o Adjustment of the Green Asset Ratio (GAR) methodology to avoid distortions o Deletion of non-relevant reporting requirements, in particular data from sectoral reporting that is not relevant for the GAR o To ensure that the actual sustainability performance of the portfolios can be adequately mapped , it should also be possible to include taxonomy-aligned activities - that do not fall under the CSRD - in both the numerator and denominator c) Simplification of the templates o Reduction in the number of reporting templates o Cancellation of the requirement to break down reporting by type of counterparty (thereof loans and advances, thereof debt securities, thereof equity instruments) +++ Since the Taxonomy was introduced, it has become evident that the comprehensive, technical, and rigid criteria significantly limit the taxonomys effectiveness. Additionally, the currently required metrics do not allow for reliable conclusions about the actual impact the portfolios have on the environment. Before finalizing the Delegated Acts, the European Commission should thoroughly analyze the current shortcomings of the taxonomy and balance simplification efforts with the need to maintain the robustness and credibility of the framework.
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Meeting with René Repasi (Member of the European Parliament)

19 Mar 2025 · Sustainability Omnibus

Meeting with Pascal Canfin (Member of the European Parliament, Shadow rapporteur)

19 Mar 2025 · Omnibus I

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

18 Mar 2025 · Kleinanlegerstrategie

Meeting with Markus Ferber (Member of the European Parliament)

20 Mar 2024 · Current issues in finances and coming legislative period

Meeting with Peter Liese (Member of the European Parliament)

31 Jan 2024 · LULUCF, ESR, ETS, CRCF, IED

Meeting with Rasmus Andresen (Member of the European Parliament, Shadow rapporteur)

25 Jan 2024 · ESG ratings

Meeting with Norbert Lins (Member of the European Parliament)

24 Jan 2024 · Finanzierungspraxis im Agrarsektor