Anbei übermitteln wir die Stellungnahme der BRAK zu den beiden Kernrechtsakten des Digital-Omnibus-Pakets. Es handelt sich dabei um eine erste Einschätzung zu besonders wichtigen Punkten. Wir behalten uns vor, noch einmal umfassender Stellung zu nehmen.
BUN
Bundesrechtsanwaltskammer
Industry association · Germany · EU Transparency Register 25412265365-88
12
positions filed
in the 665 files tracked
11
legislative files
of 665 tracked
12
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 410 trade unions and professional associations on this site, they rank #44 by legislative files engaged, a count of participation, not a measure of influence.
6.8
declared lobbying FTE
self-declared
€300K+
declared costs / yr (floor)
0
EP accreditations
as declared to the register
2011
in the register since
Declares membership of
- International Bar Association (IBA)
- Union Internationale des Avocats (UIA)
- Council of Bars and Law Societies of Europe (CCBE)
- Bundesverband der Freien Berufe (BfB)
- European Criminal Bar Association (ECBA)
Self-declared to the EU Transparency Register (snapshot 14 Oct 2026).
- Register category
- Trade unions and professional associations
- 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
Bundesrechtsanwaltskammer filed 12 positions between 4 May 2021 and 25 Jun 2026, across 11 of the 665 legislative files tracked here, attaching a full position paper 12 times.
2021 · 1 filed2022 · 1 filed2023 · 4 filed2024 · 2 filed2025 · 1 filed2026 · 3 filed
What they argued
Stellungnahme Nr. 66 Januar 2026 Registernummer: 25412265365-88 Stellungnahme zum Vereinfachungspaket für den Digitalbereich „digitaler Omnibus“ Mitglieder des Ausschusses Datenschutzrecht RA Klaus Brisch, LL.M. RA Malte Dedden RA Michael Dreßler RA Peter Hense RA Prof. Dr. Armin Herb (Vorsitzender) RAin Heike Kraus, MLE, LL.M RA Jörg Martin Mathis RAin Simone Rosenthal RA Dr.
Filed in German · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
In principle, the Federal Bar Association (Bundesrechtsanwaltskammer, BRAK) recognises the objective of creating a single, digital form of company for the European single market with EU Inc., in particular to promote start-ups across borders and strengthen the EU’s competitiveness.
Filed in German · English published by the European Commission
see attached document. The Federal Bar Association would like to thank you for the possibility of an opinion. The draft is comprehensive and ambitious. Its implementation would have a significant impact on: all users and providers of everyday products and related services in a Multitude of situations. It should be avoided that the use of these products: this makes it more difficult.
Filed in German · English published by the European Commission
Stellungnahme Nr. 35 April 2021 Registernummer: 25412265365-88 Digital Markets Act – Opinion of BRAK Mitglieder des Ausschusses Kartellrecht RAin Dr. Ellen Braun, LL.M. (Berichterstatterin) RA Dr. Matthias Karl, LL.M. RA Dr. Moritz Wilhelm Lorenz (Berichterstatter) RA Dr. Andreas Lotze RA Dr. Martin Schwarz RAin Dr. Dominique Wagener RA Dr.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The Federal Bar Association (BRAK) is grateful for the opportunity to comment on the European Commission’s proposal for a regulation to combat late payment in commercial transactions. The attached opinion opposes the abolition of the maximum payment period of 60 days and raises concerns about the introduction of enforcement authorities: An administrative area would be created which would create a non-structural…
Filed in German · English published by the European Commission
Ladies and gentlemen, the Bundesrechtsanwaltskammer (Bundesrechtsanwaltskammer – BRAK) is grateful for the possibility of taking a position on the proposal for a legislative initiative on cross-border activities of associations with the attached opinion.
Filed in German · English published by the European Commission
Please find the feedback of the Federal Bar Association attached. It is a joint feedback on the Directive (p. 3-6) and the Regulation (p. 6) with a common intro (p. 2-3) and common conclusions (p. 7). We want to upload this document as well as a feedback for Regulation. Please do not hesitate to get back to us if you have any questions. Many thanks.
Filed in German · English published by the European Commission
The Federal Bar Association gives its opinion on the European Commission’s proposal for a directive on combating sexual abuse and sexual exploitation of children in the attached document. It warmly welcomes the intention of the proposal and the innovations it envisages in the field of prevention and education.
Filed in German · English published by the European Commission
see Annex The Federal Bar Association is the umbrella organisation for legal self-government. It represents the interests of the 28 bar associations and thus of the entire legal profession in the Federal Republic of Germany. I. Publication of comprehensive information on beneficial owners raises fundamental concerns.
Filed in German · English published by the European Commission
Please find the feedback of the Federal Bar Association attached. It is a joint feedback on the Directive (p. 3-6) and the Regulation (p. 6) with a common intro (p. 2-3) and conclusions (p. 7). We want to upload this document as well as a feedback for Directive. Please do not hesitate to get back to us if you have any questions. Many thanks.
Filed in German · English published by the European Commission
The German Federal Bar Association is an umbrella organisation for lawyers and their associations. It represents the interests of the 28 bar associations, and thus of the entire Bar of the Federal Republic of Germany, with around 166.000 lawyers vis-à-vis authorities, courts and organisations at national, European and international level. See attached opinion
Filed in German · English published by the European Commission
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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.