Deutsche Börse Group

Deutsche Börse Group (DBG) welcomes the creation of a 28th regime in the form of an EU Inc., designed to enable innovative companies to operate under a single and harmonized EU framework for company law. We support this initiative as it holds the potential to reduce fragmentation across the 27 national company laws, lower administrative hurdles, improve financing options, facilitate cross-border business activities…

The Single Market is one of the EUs greatest strengths, yet the lack of unified corporate law continues to hinder cross-border business activity. Fragmentation across 27 national legal systems creates complexity, limits growth, and undermines Europes global competitiveness.

Deutsche Börse Group (DBG) welcomes the opportunity to comment on the draft Delegated Regulation containing revised ESRS. As a leading European market infrastructure provider, DBG is committed to fostering a robust, transparent and efficient EU single market for sustainable finance. An effective, proportionate and globally aligned sustainability reporting framework is an essential cornerstone for this.

Deutsche Börse Group Comments on the European Commission´s legislative proposal for harmonised rules on Artificial Intelligence (Artificial Intelligence Act) and amending certain Union legislative acts Frankfurt am Main, 6 August 2021 Introduction Deutsche Börse Group (DBG) in its capacity as a financial market infrastructure provider uses modern IT and technological solutions to operate, and service the financial…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Deutsche Börse Group (DBG) welcomes the European Commissions proposal to amend the Sustainable Finance Disclosure Regulation (SFDR). The SFDR has been instrumental in enhancing transparency in sustainable finance, but its implementation has also revealed significant challenges, including legal uncertainty and undue complexity, which have hindered its effectiveness and created burdens for market participants.

Deutsche Börse Group (DBG) welcomes the ECs review of the SFDR alongside its continued simplification and burden reduction efforts within the sustainable finance framework. Firstly, we fully agree with the objectives of the SFDR in fostering an investment in sustainable finance and secondly, we share the critique raised by various stakeholders on the shortcomings of the current framework.

Deutsche Börse Group (DBG) would like to thank the European Commission for the opportunity to comment on the proposal for a Corporate Sustainability Reporting Directive (CSRD). We welcome the further development of the requirements for sustainability-related corporate reporting, both as a market infrastructure provider as well as a listed and thus reporting company.

As a market infrastructure provider, Deutsche Börse Group (DBG) is subject to several EU reporting frameworks and non-EU regimes. Against this background, DBG welcomes the European Commissions commitment to streamline the reporting landscape to reduce the reporting burden and make reporting more efficient.

Deutsche Börse Group supports the European Commissions focus on enhancing the competitiveness of the EU banking sector and capital markets. A robust, efficient, and integrated financial sector is essential to fund the green and digital transitions, support European businesses, and strengthen the EUs strategic autonomy.

Deutsche Börse Group (DBG) welcomes the opportunity to provide feedback on the European Commission's Call for Evidence regarding the 'Omnibus' initiative to streamline tax rules. We support the goal of improving the business environment in the EU by reducing administrative burdens and enhancing tax certainty.

Deutsche Börse Group supports the European Commission's Citizens' Omnibus Initiative to reduce administrative burdens for citizens. We wish to draw attention to a critical area for simplification within financial services, where retail investors face significant onboarding frictions when accessing transparent, regulated markets.

Deutsche Börse Group (DBG) would like to express appreciation for the opportunity to respond to the proposed "Faster and Safer Relief of Excess Withholding Taxes" Initiative (FASTER). As a company advocating for a stronger European capital market, we firmly believe that this initiative is a crucial step, aiming to address tax barriers to cross-border investment, simplify taxation, and introduce a common EU-wide…

ISS STOXX appreciates the opportunity to provide input to the European Commissions Call for Evidence on the possible review of the Shareholder Rights Directive (SRD or Directive). We offer our comments in our capacity as a provider of proxy research and vote recommendations (a proxy advisor, as defined by Article 2(g) of the SRD), and from the vantage point of serving a range of institutional investor clients…

Deutsche Börse Group (DBG) supports the objectives of the Shareholder Rights Directive (SRD II) to enhance shareholder engagement, improve corporate governance, and facilitate cross border investment. However, we would like to highlight that fragmented national implementation, incomplete standardization, and persistent manual processes have significantly limited the Directives effectiveness in practice.

Deutsche Börse Group appreciates the opportunity to provide feedback on the roadmap for a European Single Access Point (ESAP) for financial and non-financial information publicly disclosed by companies as part of the CMU Action Plan. Progressing on the CMU is not only decisive for delivering Europe's New Green Deal and Digital Agenda, but also to support a healthy and sustainable post-pandemic recovery.

Deutsche Börse Group (DBG) welcomes the opportunity to respond to ECs proposal on the Listing Act. A strong European capital market is more necessary than ever. EU capital markets underperform compared to other jurisdictions. This reduces the EUs role as a financial centre and will weaken the European economy. Lower barriers for going public and increased incentives for staying public would be the right answer.

Deutsche Börse Group (DBG) welcomes the proposed Delegated Act on SME Research. We share the Commission’s view that exempting small and mid-cap enterprises (SMEs) from the unbundling rule will contribute to an increase of research coverage for those. Moreover, we agree with the definition of SMEs (market capitalisation of < EUR 1 bn over 12 months period).

1. Critical benchmarks: Deutsche Börse Group (DBG) does not consider that competent authorities should have broader powers regarding methodology modifications for critical benchmarks. On the contrary, we consider that this could create uncertainty for users regarding the continued provision of such benchmarks.

Deutsche Börse Group strongly welcomes the European Commissions resolve to make the current transitory NSFR regime for securities financing transactions (SFTs) permanent. Upon the implementation of the NSFR in June 2021, European banks did not face significant challenges in adapting to the requirements due to the ECBs generous Targeted Long Term Refinancing Operations (TLTRO).

Deutsche Börse Group appreciates the opportunity to provide feedback on the roadmap for a retail investment strategy for the EU as part of the CMU Action Plan. Over the course of the last years, in particular in 2020, we have seen positive developments in EU retail participation as well as a change in investor behavior.

Deutsche Börse Group (DBG) appreciates the opportunity to give feedback on the roadmap regarding the review of the MiFID II/MiFIR framework. We share the European Commission’s view that the targeted MIFID II/MiFIR review is urgently needed to improve the functioning and transparency of EU financial markets.