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Deutsches Aktieninstitut

Deutsches Aktieninstitut represents listed companies and capital market participants in policy dialogue at national and European levels.

Lobbying Activity

Meeting with Elena Arveras (Cabinet of Commissioner Maria Luís Albuquerque)

23 Jan 2026 · ESRS standards

Meeting with Angelika Niebler (Member of the European Parliament)

10 Dec 2025 · EFRAG-Entwurf: ESRS

Response to EU taxonomy - Review of the environmental delegated act

5 Dec 2025

Further Simplifications required: In its statement, Deutsches Aktieninstitut welcomes the EU Commissions objective of reducing regulatory burdens arising from the regulation and its delegated acts. For the Technical Screening Criteria (TSC) and the Do-No-Significant-Harm (DNSH) criteria, we advocate (a.o.) for adjustments in the sectors of traffic and transport as well as new buildings and manufacture of low carbon technologies. Furthermore, we believe that companies should be allowed to report under the EU Taxonomy on a voluntary basis. Regarding the proposed 10 percent materiality threshold for economic activities, additional guidance from the EU Commission is necessary to bring about the intended simplification. Please find our Statement attached in PDF.
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Meeting with Marion Walsmann (Member of the European Parliament)

3 Dec 2025 · Omnibus 1

Meeting with Tatyana Panova (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

3 Nov 2025 · EU Listing Act and SIU Strategy

Meeting with Bernd Lange (Member of the European Parliament, Committee chair)

22 Sept 2025 · General exchange of views

Meeting with Angelika Niebler (Member of the European Parliament)

2 Sept 2025 · EU banking policies

Meeting with Marion Walsmann (Member of the European Parliament)

22 Jul 2025 · current legal policy issues

Deutsches Aktieninstitut urges tax incentives for EU savings accounts

8 Jul 2025
Topic — The Commission is developing a European blueprint for retail savings and investment products.
Message — The association demands robust tax incentives and access to a wide range of equity products like shares and ETFs. They insist on maximum flexibility, opposing any minimum holding periods or limits on annual investment amounts.123
Why — Promoting these accounts would funnel more retail capital into the stock market and initial public offerings.4
Impact — National governments would lose tax revenue and face pressure to overhaul public pension systems.56
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Meeting with Nicolo Brignoli (Cabinet of Commissioner Valdis Dombrovskis)

3 Jul 2025 · Omnibus

Response to Savings and Investments Union: Directive fostering EU market integration and efficient supervision

5 Jun 2025

Deutsches Aktieninstitut welcomes the EU Commissions evident commitment to developing capital markets in the European Union and strengthening their integration. As thoroughly analysed, liquid and efficient capital markets are essential for the innovation and competitiveness of European companies. Without robust capital markets, financing the digital and sustainable transformation will not succeed. Please find therefore attached our reponse to this Call of Evidence reiterating on a few points raised in our broader position paper "Empowering Europe: Fast-Tracking the Savings and Investment Union in which we have outlined a coherent policy for the Savings and Investment Union.
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Deutsches Aktieninstitut urges alignment of EU sustainable finance rules

30 May 2025
Topic — This consultation reviews EU rules on sustainable finance disclosure to simplify reporting requirements.
Message — The organization wants reporting obligations to be fully aligned with existing corporate sustainability standards. They call for reducing reported impacts to mandatory ones and applying a single importance test.123
Why — Consistent rules would lower administrative costs by removing duplicative sustainability reporting requirements.45
Impact — Environmental groups lose detailed data if companies stop reporting on non-mandatory impacts.67
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Meeting with Ilhan Kyuchyuk (Member of the European Parliament) and ExxonMobil Petroleum Chemical and TOYOTA MOTOR EUROPE

15 May 2025 · Omnibus 1 package & simplification efforts

Meeting with Engin Eroglu (Member of the European Parliament)

14 May 2025 · Wettbewerbsfähigkeit europäischer Unternehmen und der EU als Wirtschaftsstandort

Meeting with Martin Merlin (Director Financial Stability, Financial Services and Capital Markets Union) and Association Française des Entreprises Privées / French Association of Large Companies and

8 Apr 2025 · Commission Communication on the Savings and Investments Union (SIU) and Commission Omnibus Simplification package proposals concerning the Corporate Sustainability Reporting Directive (CSRD)

Meeting with Arba Kokalari (Member of the European Parliament)

28 Mar 2025 · Savings and Investments Union

Deutsches Aktieninstitut Urges Making EU Taxonomy Reporting Voluntary

26 Mar 2025
Topic — The consultation seeks to simplify EU sustainability reporting and reduce data requirements for companies.
Message — The group recommends turning the EU Taxonomy into a voluntary tool for non-financial companies. They suggest focusing only on relevant financial data and deleting operating expense indicators.123
Why — This would reduce the high costs and efforts of maintaining complex data systems.4
Impact — Environmental groups lose oversight if strict requirements for hazardous chemicals are deleted.56
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Response to EU Start-up and Scale-up Strategy

14 Mar 2025

1. Do you agree that startups and/or scaleups face the hurdles identified in this document? As Deutsches Aktieninstitut, the association representing German listed companies dedicated to promoting equity culture and strengthening the capital market in Germany, we recognize the significant hurdles that startups and scaleups face, particularly in accessing finance, navigating regulatory burdens, and overcoming market fragmentation. In our work, we focus on Initial Public Offerings (IPOs) as an exit strategy, which is an important part of a well-functioning venture and growth capital ecosystem. For an adult start-up, the stock exchange is the continuation of growth financing. Venture capital ensures that a broad range of companies are ready for an IPO during the expansion of their business models. In turn, an IPO as exit route offers venture capital investors a very attractive opportunity to sell their shares and invest the freed-up money in other start-ups. So far, the potential of IPOs in the EU has not yet been fully utilised. For example, we only counted 9 IPOs in Germany in 2023 and 2024. To boost IPOs and provide more capital in the later-stage financing, transforming a startup into a stock-listed growth company, more household savings should be channeled into capital market investments. Therefore, we strongly support initiatives like the Savings and Investment Union (SIU), which aims to improve IPOs and stock listings. See our position paper attached. 2. Are there any additional hurdles faced by startups and/or scaleups? To further develop a well-functioning venture and growth capital ecosystem, we need more measures to increase IPO numbers in the EU. This is a general task of establishing a culture of equity/growth capital in the EU. This includes promoting equity/venture capital investments through pension system reforms, creating a label for an EU long-term savings-product, promoting financial literacy among the population, decreasing regulatory burdens which hinders companies tapping capital markets, and providing a growth friendly corporate law e.g. by setting a 28th regime. 3. What actions do you think the EU and/or its Member States should take to address these hurdles? To enhance IPO attractiveness across the EU, please see our recommendations in our position paper attached. In addition to promoting IPOs, we propose the following strategic measures: Enhance capital raising and market access: Improve start-ups' ability to raise capital through initiatives like the WIN program in Germany, an alliance of business, associations, politicians and the Kreditanstalt für Wiederaufbau (KfW) committed to invest EUR 12 bn. until 2030 in the German venture and growth capital ecosystem. Develop a European marketplace for direct secondary transactions: Create a marketplace for trading shares of late-stage and pre-IPO startups, allowing broader investor participation while ensuring protection. Align tax regimes to attract talent: Promote employee shares with tax incentives and align tax regimes across the EU to support start-ups in attracting talent. Promote financial education and public-private collaboration: Encourage financial education programs and strengthen public-private partnerships to equip entrepreneurs and investors with the knowledge to navigate capital markets effectively. Increase attractiveness of SME Growth Markets: Provide a more flexible regulatory regime which fits the needs of small and mid-cap companies.
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Meeting with Michael Hager (Cabinet of Commissioner Valdis Dombrovskis)

13 Mar 2025 · Simplification and competitiveness of the financial services sector

Meeting with Martin Merlin (Director Financial Stability, Financial Services and Capital Markets Union)

13 Mar 2025 · Exchange of views on UCITS and the current Omnibus package on simplifying EU rules on sustainability reporting

Response to Savings and Investments Union

5 Mar 2025

For the Savings and Investment Union to succeed, a consistent overall strategy is essential. This strategy should bolster the European investor base, address the needs of listed companies in the capital market and efficiently connect the supply and demand sides of the market. Key elements of such a strategy include increasing the use of capital market investments in pensions and wealth building, facilitating investment advice by reducing bureaucratic requirements, optimizing the use of existing capital pools by reforming diversification rules for investment funds and improving liquidity pooling for individual shares, simplifying reporting obligations for listed companies, better enabling capital raising, and implementing a practical and uniform supervisory approach. The position paper of Deutsches Aktieninstitut attached outlines these points in more details.
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Meeting with Andreas Schwab (Member of the European Parliament)

4 Mar 2025 · Omnibus-Vorschlägen und Berichtspflichten

Meeting with Nicolo Brignoli (Cabinet of Commissioner Valdis Dombrovskis)

3 Mar 2025 · Omnibus

Meeting with Ilhan Kyuchyuk (Member of the European Parliament)

17 Feb 2025 · Importance of simplification for EU business

Meeting with Marcel Haag (Director Financial Stability, Financial Services and Capital Markets Union) and Association Française des Entreprises Privées / French Association of Large Companies and

6 Feb 2025 · Omnibus Proposal

Meeting with Cristina Dias (Cabinet of Commissioner Maria Luís Albuquerque), Elena Arveras (Cabinet of Commissioner Maria Luís Albuquerque), Larisa Dragomir (Cabinet of Commissioner Maria Luís Albuquerque) and

6 Feb 2025 · Introductory meeting to present the organisations and their work

Response to Applying a unique identifier for public transparency of OTC derivatives

10 Jul 2024

Please find attached our position paper
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Meeting with Nicolo Brignoli (Cabinet of Executive Vice-President Valdis Dombrovskis)

31 May 2024 · Meeting with Deutsches Aktieninstitut e.V.

Meeting with Werner Stengg (Cabinet of Executive Vice-President Margrethe Vestager)

2 May 2024 · EU's priorities on digital and technological development

Meeting with Svenja Hahn (Member of the European Parliament) and BUSINESSEUROPE and

21 Feb 2024 · Stakeholder Roundtable on Late Payment Regulation

Response to Postponement of deadlines within the Accounting Directive for the adoption of certain ESRS

19 Dec 2023

Dear Madam, Dear Sir, As association of German listed and capital markets-oriented companies, Deutsches Aktieninstitut represents almost 90 percent of the DAX-market capitalization. We welcome the opportunity to comment on the Proposal for a decision amending Directive 2013/34/EU as regards the time limits for the adoption of sustainability re-porting standards for certain sectors and for certain third-country undertakings. Non-financial undertakings are currently facing major challenges in implementing the ESG reporting require-ments arising from the CSRD and the Taxonomy Regulation simultaneously. With the first set of ESRS alone, companies will have to disclose more than 1.100 ESG data points which is an immense amount of data to be collected and disclosed. Additional data points will become mandatory in the future when EFRAG develops sector-specific and other standards. The implementation of these requirements will be linked to a high administrative effort for companies. Both the ESRS and the Taxonomy have to be implemented with short implementation deadlines. In order to achieve a proper implementation of the ESRS, companies need support in the form of guidance and guidelines. We therefore welcome EFRAGs ongoing efforts to draft non-authoritative guidance, such as the Materiality Assessment Implementation Guidance and the Value Chain Implementation Guidance, and we encourage EFRAG to continue its works on implementation guidance. As correctly referred to in the above-mentioned proposal for a decision amending Directive 2013/34/EU, companies should be given sufficient time to prepare for new reporting requirements. Postponing the adoption date of sector-specific ESRS will allow the affected companies to focus on the implementation of the first set of ESRS adopted on 31 July 2023. It also ensures that EFRAG has sufficient time to develop high-quality sector-specific ESRS and limit the reporting requirements for companies. The development of the sector-specific ESRS should take place in close cooperation with companies. We welcome amending the Directive 2013/34/EU and are in favor of setting the deadline for the Commission to adopt sector-specific ESRS by way of delegated acts by 30 June 2026. We would be grateful if you could consider our comments in the political discussions and remain at your disposal for any questions. Yours faithfully Jessica Göres Head of Sustainability Reporting
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Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur) and Bundesverband der Deutschen Industrie e.V. and Bundesvereinigung der Deutschen Arbeitgeberverbände e.V.

30 Nov 2023 · Corporate Sustainability Due Diligence

Deutsches Aktieninstitut opposes mandatory EU late payment limits

26 Oct 2023
Topic — The EU is revising rules to tackle delays in commercial payments.
Message — The group rejects a mandatory 30-day payment term and automatic interest. They advocate for contractual flexibility to respect individual business needs.12
Why — Companies would avoid administrative burdens and maintain flexible business financing.34
Impact — Small suppliers lose predictable cash flow when payments are significantly delayed.5
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Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur) and Handelsverband Deutschland

13 Sept 2023 · Corporate Sustainability Due Diligence

Deutsches Aktieninstitut Urges Stricter Standards for ESG Rating Providers

11 Aug 2023
Topic — The initiative aims to improve the reliability and transparency of environmental, social, and governance ratings.
Message — The group wants controversy reports included in the rules and a formal right for companies to correct errors before ratings go public.123
Why — This would reduce the heavy cost of fixing misleading scores based on incorrect or incomplete data.4
Impact — ESG data and rating providers would face increased compliance costs and stricter operational oversight.56
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German listed companies demand simpler EU Taxonomy reporting rules

3 May 2023
Topic — This consultation establishes classification criteria for environmentally sustainable economic activities.
Message — The organization requests that the publication of the OpEx KPI 'should not be mandatory' and seeks to revert to 'former reporting templates'. They urge for consistency with existing law and the removal of 'unreasonably high' verification requirements for pharmaceuticals and chemicals.123
Why — Simpler rules would significantly 'reduce the complexity' and costs associated with reporting and verification.45
Impact — Financial institutions and data users lose access to detailed operational expenditure and sustainability data.67
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Deutsches Aktieninstitut urges simpler EU taxonomy reporting rules

3 May 2023
Topic — This consultation defines criteria for economic activities contributing to EU environmental objectives.
Message — The association proposes making operational expenditure reporting voluntary when not material to businesses. They request returning to previous reporting templates to avoid additional administrative effort. Technical criteria should align with existing EU laws like REACH and industrial emissions.123
Why — Simplifying templates and verification would lower compliance costs and reporting complexity for firms.456
Impact — Transparency advocates lose access to standardized data regarding companies' sustainable operational spending.7
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Response to Facilitating small and medium sized enterprises’ access to capital

28 Mar 2023

Deutsches Aktieninstitut welcomes the draft of the EU Listing Act of December 7th, 2022. We support the European Commission in its intention to reduce the bureaucratic burden, improve legal certainty and reach real improvement for the practice of listed companies. This objective is fully shared by us. It should be implemented with consequence and consistency regarding both the market the Market Abuse Regulation (MAR) and the Prospectus Directive. The key issue regarding MAR is the obligation of issuers to publish inside information on processes that typically occur in stages (such as M&A situations). We note that the wording of the proposal allows for a variety of interpretations, which creates new uncertainties and could even lead to new compliance risks and costs for issuers. Thus, it should become clear from the wording that in a protracted process only the final event shall be disclosed immediately after it has actually occurred. Regarding the Prospectus Regulation we fully support the objectives to make it easier and cheaper for issuers to draw up a prospectus and to introduce sizable simplifications to the prospectus requirements in cases where the issuer is already known to investors and a lot of information is already publicly available (follow-on issuances). In order to achieve these objectives, the proposed simplifications of the EU Follow-up prospectus should however also be applied to the base prospectus which are used for bond issuances. In addition, an in-depth analysis of the Proposal reveals that certain changes, likely unintentionally, introduce very significant difficulties, legal ambiguities and liability risks for issuers which need to be resolved. The attached file summarises our comments in detail.
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Meeting with Eva-Maria Alexandrova Poptcheva (Member of the European Parliament, Shadow rapporteur)

28 Mar 2023 · Listing Act

Deutsches Aktieninstitut opposes removing intra-group transaction reporting exemptions

20 Mar 2023
Topic — Review of EU rules for central counterparties and derivative market participants.
Message — The group opposes removing the reporting exemption for internal group transactions. They argue these trades are risk-neutral and offer no regulatory benefit. They suggest simplifying the notification process instead of abolishing the exemption.123
Why — Maintaining the exemption prevents significant administrative burdens and costs for businesses.45
Impact — Regulators lose data on the potential interconnectedness of companies within the financial system.6
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Meeting with Eva-Maria Alexandrova Poptcheva (Member of the European Parliament, Shadow rapporteur) and Association Française des Marchés Financiers

15 Mar 2023 · Listing Act

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness), Katherine Power (Cabinet of Commissioner Mairead Mcguinness) and Association Française des Entreprises Privées / French Association of Large Companies

9 Mar 2023 · Sustainable Finance

Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur) and EUROPEAN TRADE UNION CONFEDERATION and

7 Nov 2022 · Corporate Sustainability Due Diligence

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

13 Sept 2022 · Corporate Sustainability Due Diligence

Deutsches Aktieninstitut Urges More Realistic EU Due Diligence Rules

23 May 2022
Topic — Proposed EU directive for corporate sustainability due diligence regarding human rights and environment.
Message — The group demands clear definitions of business relationships to ensure legal certainty. They suggest monitoring risks every three years rather than the proposed annual requirement. They strongly oppose independent civil liability and expanded duties for company directors.123
Why — This would lower compliance costs and shield companies from unpredictable legal liabilities.456
Impact — Poorer countries might lose trade partners as European firms withdraw to avoid risks.78
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Meeting with Axel Voss (Member of the European Parliament)

11 Nov 2021 · Corporate Sustainability Reporting Directive

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis) and Association Française des Entreprises Privées / French Association of Large Companies and

12 Oct 2021 · Sustainable Corporate Governance Initiative

Meeting with Agnieszka Drzewoska (Cabinet of Commissioner Mairead Mcguinness) and Wirtschaftskammer Österreich and Association Française des Entreprises Privées / French Association of Large Companies

28 Sept 2021 · Investment protection and facilitation.

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis) and Wirtschaftskammer Österreich and Association Française des Entreprises Privées / French Association of Large Companies

28 Sept 2021 · Investment protection and facilitation

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

27 Sept 2021 · Non-financial reporting/CSDR rules

Response to EU Standard for Green Bond

20 Sept 2021

Deutsches Aktieninstitut welcomes the proposed voluntary nature for the Regulation on European green bonds (EU GBS) and the intention to ensure its co-existence with existing green bond standards. Furthermore, we support the alignment of the EU GBS with the EU Taxonomy. This is a distinctive feature of the planned EU GBS and a major difference from the previous market standards for green bonds. However, there is still room for improvement in three notable areas 1. The EU GBS needs flexibility in the provisions for the green bond alignment with the Taxonomy where the Technical Screening Criteria may not be directly applicable or the criteria have not yet been developed. 2. Grandfathering provisions are needed: EU green bonds should maintain their status until maturity, provided they met the eligibility criteria at the time of issuance. Newly updated taxonomy criteria should not be relevant for the status of the bond in order to provide legal and economic certainty for both issuers and investors as well as to make the EU label attractive. 3. The required reporting deadlines are too difficult to meet in practice. The initial 30 days period for the preparation of the allocation report is too ambitious in comparison to the deadlines of financial reporting according to Art. 4 para. 1 Directive 2004/109 allowing 120 days for the preparation of an annual financial report. The EU GBS should be brought in line with existing rules and market practice. A detailed analysis of the regulatory proposal can be found in the attached document.
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Response to Revision of Non-Financial Reporting Directive

14 Jul 2021

Dear Madam or Sir, please find enclosed the feedback of Deutsches Aktieninstitut on the Proposal for a Corporate Sustainability Reporting Directive. We stay at your disposal for any questions. Kind regards, Jan Bremer
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Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness) and Association Française des Entreprises Privées / French Association of Large Companies and

7 May 2021 · sustainable corporate governance

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis) and Association Française des Entreprises Privées / French Association of Large Companies and

7 May 2021 · Sustainable corporate governance

Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

Dear Mr. Haag, Deutsches Aktieninstitut, the organization of listed companies in Germany and other entities committed to the development of European capital markets, follows the debate on the development and progression of sustainable finance with close interest. We would like to thank the European Commission for the occasion to comment on the draft Delegated Acts (DAs) for the first two environmental objectives of the Taxonomy. The Taxonomy is bound to largely affect the activities of issuers across all industries. From this perspective, Deutsches Aktieninstitut doubts that the draft DAs will contribute to turning the Taxonomy into a landmark for the transition to a sustainable low-carbon economy. We would like to point at the following aspects which can be found in the attached letter. Yours sincerely Jan Bremer and Dr. Uta-Bettina von Altenbockum
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Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis) and Association Française des Entreprises Privées / French Association of Large Companies and

18 Dec 2020 · Sustainable finance

Response to Review of the Benchmark Regulation

28 Sept 2020

Financial benchmarks play a key role in global financial markets and day-to-day activities of treasury departments of non-financial companies (NFC). They are an important part of the risk management strategies, for example to protect NFCs from exchange rate risks, commodity price risks or interest rates fluctuations. Deutsches Aktieninstitut therefore welcomes the initiative of the EU Commission to improve the Benchmark Regulation (BMR), on two key points: (1) the exemption of specific foreign exchange benchmarks and (2) the introduction of statutory replacements for discontinued or unrepresentative financial benchmarks. The proposed amendments are both a step in the right direction, although from the perspective of NFCs they both require further refinement and extension. In particular, the proposal to exempt certain Non-EU-benchmarks should be extended to other classes of benchmarks (most notably interest rate benchmarks). However, the proposal has missed the opportunity for a comprehensive reform of the BMR. Just as other jurisdictions have limited their regulatory regimes to the most critical or systemic benchmarks, the BMR should employ a risked based approach and focus its efforts on critical benchmarks only. This would solve a number of problems that currently arise with the BMR without jeopardizing the ultimate objective of ensuring reliability of financial benchmarks and protecting the EU economy from systemic risks. We therefore encourage policy makers to envisage such a comprehensive reform as soon as possible.
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Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur)

24 Sept 2020 · Corporate Sustainability Due Diligence

Response to Action Plan on the Capital Markets Union

17 Jul 2020

Dear Madam/Sir, please find attached the comments of Deutsches Aktieninstitut on the CMU Roadmap. Best Regards Deutsches Aktieninstitut
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Response to Review of the Benchmark Regulation

15 Apr 2020

Deutsches Aktieninstitut welcomes the opportunity to comment on the European Commission’s Inception Impact Assessment on the review of the Benchmarks Regulation (BMR). This position paper summarizes the view of German non-financial companies on the issues raised. Our view is based on discussions in the corporate finance/corporate treasury working group of Deutsches Aktieninstitut which is the central forum of opinion building for the treasury departments of the largest German non-financial companies (NFC). We welcome the initiative to improve the BMR, to “ensure the continued availability to EU users of third country benchmarks for which no suitable alternative exists in the Union” and to “improve the user-friendliness of the regime for benchmark users”. As the Commission states, the current third-country regime has proven inefficient in many different ways. The result being that EU non-financial companies risk losing access to a number of third-country benchmarks on which they depend, e.g. to hedge exposure to interest rate or FX risk in their daily business. From the perspective of a non-financial end-user of financial products, this situation is likely to lead to uncertainties in operative business and interfering with existing treasury activities. This will be exacerbated by Brexit, following which all UK administered benchmarks will become third country benchmarks with no guarantee of an equivalence decision. We believe that the BMR should take a proportionate approach, as certain benchmarks pose a far greater risk to the financial system than others do. With its unrestricted scope and the automatic ban on the use of non-qualified benchmarks, the BMR loses sight of non-financial end-users from the real economy. Against this background, Deutsches Aktieninstitut proposes following changes to the BMR: 1. The BMR should focus its efforts to critical benchmarks only. 2. EU non-significant benchmarks and their equivalent third country benchmarks should be exempt of the BMR and allowed to be used in the Union unless specifically prohibited (i.e. a reversal of the current general prohibition of benchmarks unless specifically authorised). 3. Public policy benchmarks (e.g., FX rates used in NDFs and certain interest rate swaps) should be exempt in general because they are pseudo-governmental and their prohibition would be disproportionately disadvantageous to end users. Non-significant EU and equivalent third country benchmarks as well as public policy benchmarks used in NDFs pose little risk of systemic disruption. 4. ESMA could be empowered to analyse significant EU and third country benchmarks based on their use or potential impact on EU financial markets. On this basis, ESMA could decide whether individual benchmark providers need to fulfil additional obligations. Such a regime would ensure the continued availability to EU users of benchmarks from third countries for which there is no suitable alternative in the Union and improve the user-friendliness of the system for benchmark users. In addition, it would relieve EU and non-EU administrators of regulatory hurdles alike and level the playing field.
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Response to A simplified prospectus for companies and investors in Europe

20 Dec 2018

Deutsches Aktieninstitut welcomes the opportunity to be part of improving the prospectus regime and is therefore pleased to provide feedback to the Commission’s draft delegated act to be adopted under the Prospectus Regulation (EU) 2017/1129 as regards the format, content, scrutiny and approval of the prospectus to be published when securities are offered to the public or admitted to trading on a regulated market. On the basis of the draft proposal, we have the following comments:
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Meeting with Günther Oettinger (Commissioner)

10 Oct 2018 · MFF

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

9 May 2018

Deutsches Aktieninstitut welcomes the opportunity to comment on the draft level II Regulation on the SRD II which will help to further improve and harmonise information flows between companies, intermediaries and shareholders and, in turn, will ease to practice shareholders’ rights cross border within the EU. As we understand the draft it is based on the common understanding developed in already existing cross-industry initiatives on the processing of corporate actions and general meetings. Though we basically welcome the draft, some work remains to be done before the final endorsement of the level II Regulation in order to clarify the scope and in order better explain the meaning of the terms and the processes that are envisaged. Overall, it has to be ensured that the final Regulation works together with existing company laws as well as the needs of issuers to have legal certainty on the important issue of shareholder rights, to reliably identify end investors and to comply with the new standards in a manner that is cost-efficient and takes care of existing practices to the extent possible. For detailed comments please refer to the position paper attached. The paper is based on discussions of listed companies in Germany. Note, however, that the consultation period has overlapped with the general meeting season, at least in Germany, which made it difficult to evaluate any provision in detail. The position paper attached might thus be followed up after further discussions among the German issuers affected.
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Meeting with Jan Ceyssens (Cabinet of Vice-President Valdis Dombrovskis)

23 Mar 2018 · Sustainable finance

Meeting with Markus Schulte (Cabinet of Vice-President Günther Oettinger)

4 May 2017 · CSR

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

28 Mar 2017 · Kapitalmarkt

Meeting with Markus Schulte (Cabinet of Vice-President Günther Oettinger)

20 Mar 2017 · Capital Market Union

Meeting with Ioana Diaconescu (Cabinet of Commissioner Pierre Moscovici)

31 Aug 2016 · Praparation of the participation of the Commissioner as the honoured guest at the Brussels autumn reception.

Meeting with Michael Hager (Digital Economy)

24 May 2016 · audit reform

Meeting with Markus Schulte (Digital Economy)

24 May 2016 · Corporate governance

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

15 Feb 2016 · Joint mtg on European Market Infrastructure Regulation

Meeting with Lee Foulger (Cabinet of Vice-President Valdis Dombrovskis) and Bundesverband der Deutschen Industrie e.V. and

12 Nov 2015 · Joint mtg energy assoc/Markets in Financial Instruments Directive II

Meeting with Olivier Guersent (Director-General Financial Stability, Financial Services and Capital Markets Union)

13 Oct 2015 · Capital Markets Union

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

24 Sept 2015 · Preparation of VP Katainen's attendance at event

Meeting with Sebastian Kuck (Cabinet of Commissioner Jonathan Hill)

1 Apr 2015 · Audit regulation implementation

Meeting with Sebastian Kuck (Cabinet of Commissioner Jonathan Hill)

3 Dec 2014 · Audit Regulation (537/2014)