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.
AGB
Association of German Banks
Industry association · Germany · EU Transparency Register 0764199368-97
18
positions filed
in the 665 files tracked
16
legislative files
of 665 tracked
18
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 665 consultation files tracked so far (57,774 submissions, mostly 2021–26), so an organization's real filing history is larger, not smaller.
Who they are
Among the 1518 trade and business associations on this site, they rank #196 by legislative files engaged, a count of participation, not a measure of influence.
16.2
declared lobbying FTE
self-declared
€2.3M+
declared costs / yr (floor)
5
EP accreditations
as declared to the register
2008
in the register since
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 14 Oct 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 14 Oct 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 18 positions between 22 Nov 2017 and 17 Apr 2026, across 16 of the 665 legislative files tracked here, attaching a full position paper 18 times.
2017 · 1 filed2020 · 1 filed2021 · 4 filed2025 · 6 filed2026 · 6 filed
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.
We firmly support this proposal to improve access to data relevant for investment decisions by building a European Single Access Point (ESAP). We agree with the European Commission’s considerations that investors in capital markets must have access to information about companies and financial products in order to make sound investment decisions.
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 Association of German Banks very much welcomes the opportunity to comment on the draft EU Green Bond Standard (EuGBS). In principle, we very much appriciate COM’s proposal. From our point of view, several amendments to the EuGBS are necessary in order to make EuGBS a widely used premium standard. At this point, we only highlight some key aspects and outline our further comments in an accompanying document. 1.
The Association of German Banks very welcomes the opportunity to comment on the European Commission’s Inception impact assessment on EU Green Bond Standards (EU GBS). Green bonds may prove instrumental in mobilizing the bond market for climate change solutions. The Green Bond market has considerably raised its volumes and is expected to grow further.
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…
Second try, since upload of the PDF document seems to not have worked out: The Association of German Banks welcomes the European Commission’s intention to run pilot operations to identify what adjustments need to be made to existing EU regulation of services involving the issuance, safekeeping and asset servicing, trading and settlement of DLT financial instruments and, in parallel, to develop practicable proposals…
The Association of German Banks welcomes the European Commission’s intention to run pilot operations to identify what adjustments need to be made to existing EU regulation of services involving the issuance, safekeeping and asset servicing, trading and settlement of DLT financial instruments and, in parallel, to develop practicable proposals for a suitable regulatory framework and targeted adjustments to selected EU…
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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