Deutsches Aktieninstitut welcomes the opportunity to comment on the European Commissions draft Delegated Acts amending the Climate and Environmental Technical Screening Criteria under the EU Taxonomy Regulation. We would like to highlight several aspects where the proposed TSC risk impeding rather than accelerating the transition to a decarbonised European economy.
Deutsches Aktieninstitut
Industry association · Germany · EU Transparency Register 38064081304-25
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 #168 by legislative files engaged, a count of participation, not a measure of influence.
Declares membership of
- Deutsches Aktieninstitut is a member of the pan-European issuers organisation EuropeanIssuers, the Centre for Europea…
Self-declared to the EU Transparency Register (snapshot 14 Oct 2026).
- Register category
- Trade and business associations
- Head office
- Frankfurt am Main, Germany
- EU office
- Brussels
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
Deutsches Aktieninstitut filed 21 positions between 15 Apr 2020 and 17 Sept 2026, across 18 of the 665 legislative files tracked here, attaching a full position paper 20 times.
What they argued
Further Simplifications required: In its statement, Deutsches Aktieninstitut welcomes the EU Commissions objective of reducing regulatory burdens arising from the regulation and its delegated acts. For the Technical Screening Criteria (TSC) and the Do-No-Significant-Harm (DNSH) criteria, we advocate (a.o.) for adjustments in the sectors of traffic and transport as well as new buildings and manufacture of low carbon…
Having reviewed the Draft Delegated Act revising the ESRS, as published by the European Commission in early May 2026, we acknowledge the Commissions continued efforts to make the standards more practical and less burdensome.
EU Corporate Sustainability Due Diligence Directive A balanced and proportionate EU law is needed Position paper on the Proposal for a Directive on Corporate Sustainability Due Diligence, 23 May 2022 EU CORPORATE SUSTAINABILITY DUE DILIGENCE DIRECTIVE Table of Contents Table of Contents .......................................................................................................
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Deutsches Aktieninstitut welcomes the opportunity to comment on the European Commissions draft Delegated Acts amending the Climate and Environmental Technical Screening Criteria under the EU Taxonomy Regulation. We would like to highlight several aspects where the proposed TSC risk impeding rather than accelerating the transition to a decarbonised European economy.
We welcome the review of the Sustainable Finance Disclosure Regulation (SFDR). However, we believe that further refinement of the SFDR is necessary to fully reap the benefits of the revision and unlock the potential for sustainable investing. Deutsches Aktieninstitut suggests (1) to adopt a slim set of decision-useful PAI-indicators for product-level reporting, grounded in the same datapoints as used in ESRS 2.
As association of German listed and capital markets-oriented companies as well as German CFO network, Deutsches Aktieninstitut welcomes the review of the Sustainable Finance Disclosure Regulation (SFDR). Against the backdrop of the current debate on the competitiveness of European enterprises, the review bears a unique chance to fully align the SFDR with corporate reporting requirements under the Corporate…
Europe's new Corporate Sustainability Reporting Directive – Involving companies to ensure a successful transition to a sustainable economy! Feedback on the Proposal for a Corporate Sustainability Reporting Directive, 14 July 2021 EUROPE’S NEW CORPORATE SUSTAINABILITY REPORTING DIRECTIVE Introduction Climate change and the necessary transition to a resource -conserving and climate-neutral economy require a…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Deutsches Aktieninstitut welcomes the EU Commission's initiative to take stock of the current regulatory framework of banks. Non-financial companies among our members need both a strong European capital market as envisaged with the Savings and Investments Union and a strong, competitive European banking sector that can continue to provide financial services at sufficient scale and at affordable prices.
Deutsches Aktieninstitut is concerned that implementation does not consider standard market practices in payment transactions and would create a high administrative burden for companies. Please find more detailed comments in the attached position on the proposed Late Payments Regulation.
Deutsches Aktienintitut welcomes that the European Commission has presented a comprehensive legislative package aimed at improving the integration of existing capital pools in the EU and thereby making more efficient use of them. This strengthens the opportunities for companies to finance innovation, growth and employment via the capital markets.
Deutsches Aktieninstitut welcomes the EU Commissions evident commitment to developing capital markets in the European Union and strengthening their integration. As thoroughly analysed, liquid and efficient capital markets are essential for the innovation and competitiveness of European companies. Without robust capital markets, financing the digital and sustainable transformation will not succeed.
Deutsches Aktieninstitut has followed the debate ahead of the proposal very closely from the perspective of German listed companies. It is well known that as a consequence of investors interests and needs, ESG factors and ESG ratings have become increasingly relevant for access to finance and costs of finance of companies in Europe.
Dear Madam, Dear Sir, As association of German listed and capital markets-oriented companies, Deutsches Aktieninstitut represents almost 90 percent of the DAX-market capitalization. We welcome the opportunity to comment on the Proposal for a decision amending Directive 2013/34/EU as regards the time limits for the adoption of sustainability re-porting standards for certain sectors and for certain third-country…
Deutsches Aktieninstitut welcomes the draft of the EU Listing Act of December 7th, 2022. We support the European Commission in its intention to reduce the bureaucratic burden, improve legal certainty and reach real improvement for the practice of listed companies. This objective is fully shared by us.
Deutsches Aktieninstitut welcomes the proposed voluntary nature for the Regulation on European green bonds (EU GBS) and the intention to ensure its co-existence with existing green bond standards. Furthermore, we support the alignment of the EU GBS with the EU Taxonomy. This is a distinctive feature of the planned EU GBS and a major difference from the previous market standards for green bonds.
Financial benchmarks play a key role in global financial markets and day-to-day activities of treasury departments of non-financial companies (NFC). They are an important part of the risk management strategies, for example to protect NFCs from exchange rate risks, commodity price risks or interest rates fluctuations.
Deutsches Aktieninstitut welcomes the opportunity to comment on the European Commission’s Inception Impact Assessment on the review of the Benchmarks Regulation (BMR). This position paper summarizes the view of German non-financial companies on the issues raised.
Deutsches Aktieninstitut e.V. strictly opposes the proposal to remove the exemption for the reporting requirements for the intra-group transactions. We do welcome certain improvements included in the proposal such as the exclusion of cleared derivatives from the clearing threshold calculation; limiting the clearing threshold calculation to derivative positions of group members established in the EU; the extension of…
The introduction of high-yield, share-based, and simple supplementary pensions is crucial to achieving the goals of the Savings and Investments Union. These pensions enable people to participate in the success of the European economy and increase their retirement income. At the same time, funds flow through the pension system into the European economy to finance growth, innovation, and employment.
The introduction of high-yield, share-based, and simple supplementary pensions is crucial to achieving the goals of the Savings and Investments Union. These pensions enable people to participate in the success of the European economy and increase their retirement income. At the same time, funds flow through the pension system into the European economy to finance growth, innovation, and employment.
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