Union Asset Management Holding AG
The Union Investment Group, based in Frankfurt/Main, Germany was founded in 1956, and is today one of Europe’s leading asset managers for private and institutional clients.
ID: 35378765850-63
Lobbying Activity
Response to EU taxonomy - Review of the environmental delegated act
5 Dec 2025
Union Investment thanks the European Commission for the opportunity to provide input to the review of the EU Taxonomy Climate and Environmental Delegated Acts. Please find our feedback in the attached document.
Read full responseResponse to Savings and Investments Union: Directive fostering EU market integration and efficient supervision
3 Jun 2025
Union Investment welcomes the opportunity to provide feedback to the European Commissions (EC) Call for Evidence (CfE) in addition to the parallel DG FISMA consultation. For the purposes of the CfE, we would like to highlight three key aspects: UCITS investment limits: There is currently an unlevel playing field between ETFs, for which a 20% (exceptionally 35%) issuer limit may apply and actively managed funds which are subject to a 10% limit combined with a 5/40 diversification rule. To remove this unwarranted discrepancy whilst ensuring adequate diversification, we recommend establishing an aligned 5/15/40 diversification regime for both actively managed and index-tracking funds without any differentiation amongst eligible asset classes. Additional conditions for the exercise of the 15% issuer limit would not be necessary since portfolio risk management and diversification tools and principles employed by management companies already prevent undue concentration. Asset management supervision: Centralisation makes sense in areas of the financial market that are fully harmonised and characterised by significant cross-border activities giving rise to systemic risk. These conditions are not met. We doubt that the envisaged changes to current supervisory arrangements for asset managers will reduce capital markets fragmentation, direct retail savings into capital markets or reduce the cost of cross-border fund operations in the EU. To the contrary, the set-up of mandatory new supervisory bodies (e.g. Colleges) or the transfer of direct supervisory powers from local authorities to ESMA are likely to render asset management supervision more complex and costly due to the interaction with national provisions and duplication of scrutiny. Instead, we recommend a pragmatic approach that is targeted to the underlying drivers of regulatory burdens (e.g. clarification of specific provisions in the relevant Directives and enhanced use of ESAs convergence tools, where necessary). 24-hour trading: While we are aware of the US initiatives toward 24-hour trading, our operational experience as a buy-side firm indicates that the risks and costs associated with the implementation in the EU would far exceed the benefits in terms of strengthening EU markets competitiveness. Costs would arise from, inter alia, the required additional headcount and technological bandwidth to continuously run trading desks, increase in fee expenses toward counterparties, compliance costs (e.g. DORA, MiFID, etc.), further liquidity fragmentation during certain tradable hours, the need for cross-border coordination and surveillance by venues and regulators, etc. An unaligned regulatory push toward 24-hour trading in the absence of broad support from EU market participants, including smaller and mid-sized firms, should be avoided. A prior cost-benefit analysis, comprising various options (e.g. more limited extension of trading hours or no change to current regime), is imperative.
Read full responseResponse to Revision of EU rules on sustainable finance disclosure
30 May 2025
Union Investment welcomes the opportunity to contribute to this Call for Evidence. As the asset manager within the German cooperative financial network, we managed 146.6 bn in accordance with Art. 8/9 SFDR at the end of 2024. In this regard, the SFDR review is highly relevant to us and we support the idea to establish product categories. If product categorisation is done in the right way, it can lead to a better understanding of products by investors. The success, however, depends significantly on the way in which the categorisation is structured and how the categories are used and communicated in distribution (e.g. investment advice). A mandatory and direct link to the MiFID II rules and the ESMA Guidelines on funds names using ESG or sustainability-related terms would be beneficial. The terminology used in the different texts (SFDR, MiFID, ESMA Guidelines) should be aligned to prevent unnecessary complexity and create a harmonized Sustainable Finance framework. We strongly suggest a theme-based categorisation that reflects different product types, asset classes, investor needs and objectives on sustainability via different investment strategies. Especially in the real estate sector, there is a different perspective as it is linked to the real economy and typical investment approaches such as exclusions will not lead to sustainability. The innovative categorisation approach would make it possible to consider different sustainability objectives and investor needs in an efficient and targeted manner. Aspects such as transition, sustainable investments or focusing on individual sustainability indicators can thus be implemented more effectively. The alternative proposal to make targeted changes and clarifications to the existing disclosures regime (Art. 8/9) leaves little room for different investment strategies and the implementation of thematic priorities regarding sustainability. As Art. 8/9 disclosures were not intended by the legislator as categorisations, Art. 8/9 information cannot adequately consider all investment strategies and approaches in order to meet the investors need for information. We are concerned about the potential introduction of a complex matrix structure resulting from Art. 6/8/9 which has been proposed by the Sustainable Finance Platform. Our retail sales advisors have already pointed out that the distribution of sustainable financial products is overly complicated. The concept of Art. 6/8/9 should be replaced by the product categories mentioned above, with sustainability-related disclosures only applying to products with explicit sustainability claims. It is important to maintain sustainable investments within the meaning of Art. 2(17) SFDR, e.g. assets with a SDG quota, and not limit the scope to taxonomy-compliant assets as this would create a challenging investment environment, especially for securities. High taxonomy quotas are practically impossible to achieve and data availability is limited, especially outside Europe. Moreover, the Omnibus package could lead to less taxonomy reporting. Within real estate, however, the perspective is different: The taxonomy defines sustainability and is the correct approach, as SDGs are not widely applicable in this sector and data is under the owners control and therefore available. This means that SFDR criteria should not be primarily based on the taxonomy but considered correctly for the different asset classes. Furthermore, taxonomy compliance should not be based on estimates. We rely on the delivery of real taxonomy data via data providers. Estimation methods would shift the liability which should be avoided, because it is not possible for asset managers to ensure the provision of reliable data. Besides, entity-level disclosures such as under Art. 3, 4(2)b and 5 SFDR should be fully covered by CSRD reporting requirements. This entity-level transparency does not provide benefits for investors or clients and should be omitted in favor of CSRD reporting.
Read full responseMeeting with Rasmus Andresen (Member of the European Parliament, Shadow rapporteur)
1 Oct 2024 · FiDA und RiS
Meeting with Andrea Wechsler (Member of the European Parliament)
3 Sept 2024 · EU financial policy
Meeting with Ralf Seekatz (Member of the European Parliament, Shadow rapporteur)
19 Sept 2023 · Kleinanlegerstrategie
Meeting with Sebastian Kuck (Cabinet of Commissioner Jonathan Hill)
19 Apr 2016 · presentation comp + EUVECA