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Vereinigung Baden-Württembergische Wertpapierbörse e.V.

Boerse Stuttgart Group

Boerse Stuttgart Group is the sixth largest exchange group in Europe with strategic pillars in the capital markets business and in the digital and crypto business.

Lobbying Activity

Meeting with Markus Ferber (Member of the European Parliament)

21 Jan 2026 · DLTPR Review

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

16 May 2025 · Exchange with trading venues on the integration of EU capital market

Meeting with Maria Luís Albuquerque (Commissioner) and

2 Apr 2025 · Savings and Investments Union – discussion with Swedish financial market infrastructure representatives

Meeting with Markus Ferber (Member of the European Parliament)

19 Mar 2025 · CMU

Response to Savings and Investments Union

5 Mar 2025

Putting Retail Investors and Innovation at the heart of the agenda: Boerse Stuttgart Groups proposals for a Savings and Investment Union. Europe is falling behind. Compared to the US, retail investor participation is low and a third of household wealth is held in deposit. This is money urgently needed not only for transforming of the European economy but also for wealth creation and retirement provision. We fully support the EU Commissions aim to focus action on supporting people to save better, fostering capital for innovation, unlocking digital finance and ensuring the competitiveness of the financial sector. A true Savings and Investment Union (SIU) must mobilize savings and innovate the European financial market to remain competitive with the US. To that end, Boerse Stuttgart Group proposes boosting retail investment and promote innovation in capital markets. We propose to 1) reform the Pan-European Pension Product (PEPP) into a European pension account; 2) Improve the tradability of corporate bonds within the framework of PRIIPs and simplify Prospectus Regulation; 3) Enhance the DLT Pilot Regime and 4) introduce a new "28th regime", a harmonized legal regime for pan-European financing.
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Meeting with Mattias Levin (Acting Head of Unit Financial Stability, Financial Services and Capital Markets Union)

14 Jan 2025 · Digital and crypto assets

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

12 Oct 2023 · CMU, digital transformation

Response to Retail Investment Package

28 Aug 2023

As 6th largest exchange group in Europe, Boerse Stuttgart Group welcomes the opportunity to express its views on selected topics included in the EU Commissions Retail Investment Strategy(RIS). 1) We strongly support the exclusion of corporate bonds with a make-whole call from the PRIIP regulation and ask for quick adoption of the amendment We welcome the EU Commissions proposal to amend the PRIIP regulation to the effect that financial instruments whose redemption is based on a make-whole clause should no longer be classified as PRIIP. This affects especially corporate bonds, for which make-whole clauses are widespread. Retail investors have not been able to trade simple corporate bonds with a make-whole clause that are classified as PRIIP, as most issuers do not prepare a Key Information Document (KID). Providing a KID is a pre-requisite for bonds to be distributed to retail investors. Excluding corporate bonds with a make-whole clause from the PRIIP regulation would make these corporate bonds tradable for retail investors. A big hurdle for the participation of retail investors in the capital market would be removed. This is to be welcomed strongly, as it would significantly improve the opportunities for retail investors to invest directly in bonds and diversify their portfolios. We therefore encourage policymakers to prioritize the PRIIP amendment and unlock the positive impact for retail investors. 2) We appreciate efforts to equip investors with adequate product information but see no need for additional risk warnings for particularly risky products The introduction of additional information disclosures on particularly risky products which would have to be defined by ESMA obliges investment firms to display risk warnings about potential losses from risky financial products. We welcome any regulation that provides retail investors with adequate information to enable them to make confident investment decisions. We do not think that product warnings contribute to a balanced presentation of opportunities and risks of certain products. Instead, we believe that the risk-related information already available is sufficient and provides the investor with a thorough set of information. Issuers are e.g., obliged to publish a prospectus in which various risks of the product are comprehensively presented. Also, issuers of packaged retail investment products must prepare a KID that outlines the main risks of the product in a risk indicator. Finally, there is an appropriateness test that informs retail investors whether they are suitable for certain products by giving, when appropriate, a risk warning while maintaining their freedom to decide whether to continue trading in those products. We consider these instruments as sufficient to inform the retail investor comprehensively. 3) We welcome the proposal to facilitate the switch from the non-professional to the professional client category We welcome the proposed changes to the criteria to categorize investors, in particular the introduction of a new criterion relating to relevant education or training. In general, we believe that wealth should not be the primary criterion for retail investors to be classified as professional investors since knowledge, experience, and training are more decisive factors. 4) We ask policymakers to consider a level-playing field between different execution venues when executing client orders We welcome any regulation that facilitates a level-playing field between market actors. That includes an equal regulatory regime for different execution venues and distribution channels with regards to inducements which is particularly important for the structured products market. A situation should be avoided where certain market players would be allowed to pay inducements and others not. Equally, a uniform regime should be created at the product level to avoid the situation where inducements can be paid for one asset class but not for others.
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Response to Facilitating small and medium sized enterprises’ access to capital

6 Mar 2023

In general, Boerse Stuttgart Group welcomes the objective of the Listing Act to facilitate the regulatory regime for initial public offerings (IPOs), in particular for small and medium-sized enterprises (SMEs). However, the EU Commissions proposal lacks two important issues which, in our view, should be urgently addressed: I) We have major concerns regarding Article 33(7) MiFID II and the secondary listing regime of instruments that are primary listed on SME Growth Market (GM) segments. Liquidity is a key factor for successfully using capital markets for financing growth. Issuers, liquidity providers, market operators, etc., are all aiming to ensure there is sufficient liquidity for each share on the market. On regulated markets as well as on SME GMs, liquidity can range from very low to very high for different companies. Shares in SMEs are often illiquid by nature as they have a smaller market capitalization. Splitting the order book for instruments with this liquidity profile is not a good idea. In that case, thin liquidity would lead to wider spreads and, as a result, to a deterioration of price formation. This, in turn, would have a negative impact on the SMEs ability to raise capital, both for companies already listed on an SME GM and for those that intend to go public in the future. Furthermore, a secondary listing that reaches the same group of potential investors leads to other negative consequences for the functioning of the financial market in addition to thinning liquidity. Thus, we are convinced that owners of a SME shares should always have the right to protect the order book from fragmentation and thinner overall liquidity. That is why we urge the EU legislators that article 33(7) of MiFID II needs to be amended to make it explicit that issuers admitted to trading on an SME Growth Market may only with their prior consent be admitted to trading on another trading venue. Also, ESMA has, after thorough consultation and analysis, concluded that an amendment of article 33(7) MiFID II is necessary [1], while the Listing Act proposal of the EU Commission omitted this important change without explanation. [1] ESMA, MiFID II review report on the functioning of the regime for SME Growth Markets (April 2021, here). ESMA argues that Such extension, which would allow issuers who are already admitted to trading in an SME GM, to object to being traded on another trading venue, would be beneficial in reducing the risks of fragmentation of liquidity and provide the issuer with some control over the risk of split liquidity. (p. 24) II) The proposal does not include a revision of the exemption from the prospectus requirement for a minimum denomination of EUR 100,000. This threshold is a major hurdle for retail investors to participate in corporate bond markets as it incentivizes issuers to use this exemption form preparing an onerous prospectus, often carrying more than 500 pages. However, most retail investors are usually not able to invest EUR 100,000 per security, which means that the current exemption limits their investment choice dramatically. For example, they are often not able to acquire investment-grade corporate bonds of major European companies bearing a rather low risk profile. Considering this, we observe that retail investors are, on average, only able to access a smaller pool of potential investments which makes their securities portfolio less diversified. In addition, retail investors are missing out on lucrative investment opportunities, especially now that the bond markets are providing attractive yields again. In the drafting of the Prospectus Regulation in 2015, the European Commission originally proposed the removal of the exemption from the prospectus regulation, although it did not make it into the final text. We believe regulators should consider to re-activate this position or to significantly lower the threshold to facilitate retail investors access to this important asset class.
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Response to Central securities depositories – review of EU rules

17 May 2022

Boerse Stuttgart Group is the sixth largest exchange group in Europe with strategic pillars in the capital markets business as well as in the digital & crypto business, which is the largest of all European exchange groups. As an exchange that caters the needs of retail investors, Boerse Stuttgart Group offers trading in a wide range of financial instruments, from equities, ETFs, securitized derivatives and bonds to various crypto-assets such as Bitcoin, Ethereum and others. We welcome the opportunity to comment on the CSDR Review proposal of the EU Commission. In our statement on the EU Commission’s “Targeted consultation on the review of the regulation on improving securities settlement in the European Union and on central securities depositories” in February 2021, we expressed our concerns, particularly with regard to the settlement discipline and the introduction of mandatory buy-in rules, and pointed out the urgent need for change. Thus, we strongly welcome that the EU Commission has refrained from introducing mandatory buy-ins in the current CSDR Review proposal. However, we are concerned that the EU Commission maintains the option of introducing mandatory buy-in rules at a later stage. While we understand the EU Commission’s goal of strengthening the settlement discipline in the EU capital markets, we believe that this goal must be balanced against the risks attached to the introduction of mandatory buy-in rules, especially with regards to core functionalities of market making. In Boerse Stuttgart’s market model, EUWAX AG as liquidity provider plays a vital role in providing liquidity and high quality pricing for investors. In order to do so, EUWAX AG is dependent on getting access to liquidity of external market makers and liquidity providers. The access to liquidity will decrease significantly with the introduction of mandatory buy-ins. The result would be less liquidity and wider spreads for investors. The concrete mechanisms are well outlined in the EU Commission’s impact assessment report accompanying the CSDR Review proposal on page 27: “For securities not held on their balance sheet, or which cannot be readily sourced, the introduction of mandatory buy-ins would impact the ability of market makers to make markets. To adjust for the expected cost of being bought-in, market makers will have to add a premium to their prices – which will widen the bid-offer spread (which will in turn increase cost to end-investors) – or they may simply not make an offer price in an enquiry thereby deteriorating market liquidity.” Moreover, the impact assessment refers to a situation of high market volatility, as we experienced in the peak of the COVID-19 crisis in March/April 2020. The report states that “in essence, mandatory buy-ins could have exacerbated the negative impacts linked to the crisis; in particular, they could have increased liquidity pressure and increased the costs of securities at risk of being bought-in.” In addition, we want to point out that even if disrupted settlement chains of financial instruments are resolved within the EU, the problem of delivery failures remains. This is due to the fact that many market makers such as EUWAX AG operate internationally and trade with counterparties outside the EU. Should delivery problems occur in trading outside the EU, these problems may carry over into trading within the EU. This would continue to lead to unnecessary buy-ins and market makers would bear the costs for buy-ins even though they are not responsible for the original delivery delay at all. Boerse Stuttgart Group fully shares these assessments and the centrality of market making functions articulated in the impact assessment. We urge the regulators to maintain and not hamper market making and the provision of liquidity as one of the core functionalities of stable and resilient capital markets. In any trade-off between settlement efficiency and market resilience, we believe the latter should prevail.
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