Deutsche Schutzvereinigung für Wertpapierbesitz e.V.
DSW
Die DSW hat die Aufgabe, die schutzwürdigen ideellen und materiellen Interessen der Wertpapierbesitzer wahrzunehmen.
ID: 880020819551-97
Lobbying Activity
Response to Savings and Investments Union
28 Feb 2025
DSW welcomes the European Commission's initiative to promote a savings and investment union. While the capital markets union has not yet achieved the desired results, this could be achieved by focusing on a savings and investment union. However, the following factors are crucial to this: 1. The European capital market must be made attractive to private individuals. EU citizens participation in capital markets is very lowwith much wealth held in cash and deposits (an estimated 11.5 trillion), compared to the US where capital markets are more central to wealth formation. DSW calls for simple, transparent, and cost-effective investment products (e.g. equities, ETFs, government bonds) rather than complex structured products that often carry high fees and hidden risks. We propose introducing a total cost cap and establishing an EU standard for a basic savings product and a widely diversified EU equity fund/ETF that reflects the economic development of the entire EU. We also recommend tackling market fragmentation by creating a 28th regime for bluechips, supervised by ESMA, to reduce home bias and improve liquidity. 2. Investor protection must be ensured over the entire life cycle of a product, but also of a company. To make capital markets more attractive for EU citizens, we consider it necessary to ensure a healthy level of investor protection, without unduly restricting the freedom of more experienced investors. We suggest creating a semi-professional investor category, allowing investors who opt in to receive less standardized and generic, but more relevant information. Pre-contractual information (such as the PRIIPs-KID) need to be reformed to clearly present historical performance, costs, and risks, enabling informed decision-making. Additionally, DSW proposes to introduce uniform rules on delistings and to improve EU rules on restructuring/insolvency to protect minority shareholders. We also consider it necessary to enhance transparency in enforcement, and to expand collective legal redress options to private investors. 3. Long-term savings targets, such as for retirement provision, must be linked much more closely to capital market investments. DSW stresses that tax incentives should be used to steer retirement savings into capital market investments rather than traditional, often inefficient products like life insurance or Riester pensions. We consider it is worth taking a look at various legal systems that can and should serve as best practice at the European level, particularly in the context of retirement provision.. Swedens ISK, the UKs ISAs and NESTs, Japans NISA, and Canadas TFSA/RRSP all demonstrate how flexible, tax-advantaged investments can promote private wealth creation. To enhance transparency in the selection of (retirement) products, DSW also proposes establishing a European comparison portal for retirement products that clearly categorizes options based on costs, returns, and risks, thereby helping consumers make informed choices. Lastly, DSW considers it necessary to strengthen occupational pensions through opt-out schemes, and enhanced portability of entitlements. We also suggest to foster tax-favored employee share programs. Please find our full feedback attached.
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