Executive summary The Sustainable Finance Disclosure Regulation (SFDR) is an important instrument in combating climate change. Capital flows are to be steered towards sustainable investments and greenwashing prevented through transparency. The current review of the SFDR should be used to improve transparency and comprehensibility for investors with targeted amendments.
Association of German Banks
Industry association · Germany · EU Transparency Register 0764199368-97
Counts here are a floor, never a total: they cover the 326 consultation files tracked so far (29,503 submissions, mostly 2025–26), so an organization's real filing history is larger, not smaller.
Who they are
Among the 1205 trade and business associations on this site, they rank #76 by legislative files engaged — a count of participation, not a measure of influence.
Declares membership of
- Der Bankenverband ist Mitglied bei folgenden Organisationen:
- European Banking Federation (EBF), siehe www.ebf-fbe.eu
- Deutsche Kreditwirtschaft (DK), siehe www.die-deutsche-kreditwirtschaft.de
- Europäische Bewegung Deutschland (EBD), siehe www.netzwerk-ebd.de
- Managerkreis Friedrich-Ebert-Stifung, siehe www.managerkreis.de
- Wirtschaftsrat der CDU e.V.
- Landesverband Brüssel
- siehe www.wirtschaftsrat.de
- Ost-Ausschuss der Deutschen Wirtschaft e.V., siehe https://www.ost-ausschuss.de/
- Gesellschaft zum Studium strukturpolitischer Fragen e.V., siehe https://www.strukturgesellschaft.de/index.php/wir-ueb…
- Wirtschaftsforum der SPD e.V., https://www.spd-wirtschaftsforum.de/
- European Payment Council, siehe https://www.europeanpaymentscouncil.eu/
- and 17 more
Self-declared to the EU Transparency Register (snapshot 30 Aug 2026).
- Register category
- Trade and business associations
- Registered as
- Bundesverband deutscher Banken e.V. (Bankenverband)
- Head office
- Berlin, Germany
- EU office
- Brüssel
Self-declared to the EU Transparency Register (snapshot 30 Aug 2026); cost bands are floors, not audited totals. Reused under Commission Decision 2011/833/EU.
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Their record over time
Association of German Banks filed 13 positions between 22 Nov 2017 and 17 Apr 2026, across 13 of the 326 legislative files tracked here, attaching a full position paper 13 times.
What they argued
For a Successful Quantum Act, Several Key Premises Should Be Considered: -Raising Awareness: Beyond the current focus on POC, the potential significance of quantum technologies is still not widely recognized. It is therefore essential to sharpen awareness of possible developments and impacts in order to enable informed decisions at an early stage.
The Association of German Banks welcomes the European Commissions plan to ensure that Europe can continue to compete on the global stage with a powerful, deep capital market. The Market Integration and Supervision Package (MISP) presented in December 2025 can move the EU substantially in the right direction.
With reference to the European Commission’s preliminary assessment on fairness in platform-to-business relations we suggest to address the following business practices which have an impact on the competition between platform providers and business users. Unbundling marketplace and payment services Nowadays, small online retailers often do not sell their products on proprietary shops, but via online marketplaces.
The European Commission work programme for 2026 includes a plan to evaluate the Shareholder Rights Directive (SRD) . Germany's private banks believe that continued development of SRD II, based on the fundamental principles of the savings and investment union (SIU), will play a significant role in deepening the markets and strengthening shareholders rights.
The Association of German Banks welcomes the Commissions commitment to strategic foresight and, recognizing the urgency of defining Europe's long-term role amidst shifting global power dynamics, submits this contribution to the Call for Evidence.
The German Banking Industry Committee (GBIC) fully supports the attached comments of the European Credit Sector Associations (European Association of Co-operative Banks, European Banking Federation, and European Savings and Retail Banking Group ECSAs) on the draft implementing regulation concerning the reference standards and specifications for qualified electronic archiving services in the context of European…
The German Banking Industry Committee (GBIC) fully supports the attached comments of the European Credit Sector Associations (European Association of Co-operative Banks, European Banking Federation, and European Savings and Retail Banking Group ECSAs) on the draft implementing regulation concerning reference standards for qualified certificates for electronic signatures and qualified certificates for electronic…
The German Banking Industry Committee (GBIC) fully supports the attached comments of the European Credit Sector Associations (European Association of Co-operative Banks, European Banking Federation, and European Savings and Retail Banking Group ECSAs) on the draft implementing regulation concerning the reference standards and specifications for qualified electronic ledgers in the context of European Digital Identity…
This statement is submitted by the Association of German Banks, which represents 171 banks and 21 fintech companies. These include not only major international banks but also regional and foreign banks. We would like to share observations regarding the draft implementing regulation prepared by the Commission concerning the Amendment to CIR (EU) 2024/2979, 2982, 2977, and 2980.
This statement is submitted by the Association of German Banks, which represents 171 banks and 21 fintech companies. These include not only major international banks but also regional and foreign banks. We would like to share our observations regarding the draft implementing regulation prepared by the Commission concerning the amendment to CIR (EU) 2025/848.
The German Banking Industry Committee (GBIC) fully supports the attached comments of the European Credit Sector Associations (European Association of Co-operative Banks, European Banking Federation, and European Savings and Retail Banking Group ECSAs) on the draft implementing regulation concerning the requirements for qualified trust service providers (QTSPs) providing qualified trust services in the context of…
This statement is submitted by the Association of German Banks, which represents 171 banks and 21 fintech companies. These include not only major international banks but also regional and foreign banks. We would like to share observations regarding the draft implementing regulation prepared by the Commission concerning the Amendment to CIR (EU) 2025/1569.
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Turns up on the same files
Organizations that also filed on at least two of the same consultations. A shared interest in the same dossiers — not evidence of coordination, and we do not suggest any.
- European Banking Federation · 9 files in common
- Bitkom e.V. · 8 files in common
- IDEE ECONOMICHE www.idee-economiche.it · 5 files in common
- European Telecommunications Standards Institute (ETSI) · 4 files in common
- Assocertificatori · 4 files in common
Showing 5 of 80.
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Quotes are verbatim from submissions published by the European Commission, trimmed to their opening passage and never summarized by a model. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.